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On October 28, 2005, respondent filed a Federal tax lien in
Washington County, Minnesota, relating to petitioners’ 1999
outstanding Federal income taxes.
On or about November 2, 2005, petitioners timely requested
an Appeals Office hearing, seeking to avoid or at least to
postpone respondent’s proposed levy.
In their Appeals Office hearing, petitioners requested that
respondent designate their outstanding 1999 Federal income taxes
as currently not collectible. Petitioners also represented that
because of the balloon payment due on their contract for deed in
June of 2007 they intended to sell or refinance their residence
and that funds therefrom would be used by petitioners to pay
their outstanding 1999 Federal income taxes. Petitioners also
represented that they had several business deals that at some
point might provide funds to pay their 1999 Federal income taxes.
In the Appeals Office hearing petitioners did not challenge
their underlying 1999 Federal income tax liability. Per
respondent’s request, petitioners filed Form 433-A, indicating
that petitioners’ monthly living expenses exceeded their monthly
earned income and showing their residence as their only
significant asset.
On or about April 26, 2006, respondent’s Appeals officer
advised petitioners’ representative that the proposed levy action
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Last modified: November 10, 2007