-7-
compromise. The reason for the requested extension was to file
petitioner’s 2005 income tax return. However, the filing of
petitioner’s 2005 income tax return was not a requirement of
respondent’s acceptance of the offer. The OS knew that
petitioner had requested an extension for filing his 2005 taxes.
The information that the OS needed, however, had to do with
additional information to verify and confirm the data on the
submitted OIC. Therefore, it was not an abuse of discretion to
reject petitioners’ OIC on account of their failure to submit
additional information before the Court ruled on petitioners’
pending motion for reconsideration.
We conclude that respondent may proceed with collection of
petitioners’ tax liabilities for 1985-89 and 1991-2001 because
respondent’s rejection of petitioners’ offer-in-compromise was
not an abuse of discretion.
Decision will be entered
for respondent.
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