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March 1, 2005, stating that they had decided not to submit an OIC
because they would have no way of paying the debt. Trial was
held on September 19, 2005, in New York, New York.
Following trial, the Court ordered petitioners to provide
counsel for respondent a complete Form 656, Offer in Compromise,
and an updated Form 433-A, Collection Information Statement for
Wage Earners and Self-Employed Individuals. Counsel for
respondent received petitioners’ OIC on November 15, 2005, and
sent it to an offer specialist (OS) for consideration. In the
following months, the OS requested that petitioners provide
additional information by various deadlines. Petitioners did not
meet any of these deadlines.
In April 2006, petitioners requested that the Court keep the
pending OIC open for consideration until August 15, 2006, so that
petitioner could file his 2005 income tax return. The Court
denied petitioners’ request. Thereafter, respondent returned the
pending OIC to petitioners and closed their file because
petitioners had failed to provide additional information
necessary to determine the acceptability of their offer and they
failed to verify their compliance with the estimated income tax
requirements for 2005 and 2006.
Discussion
Petitioners contend that respondent’s refusal to consider
their offer-in-compromise submitted on November 15, 2005, for the
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