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requested that petitioners be given more time to submit
information to be considered. Ms. Cochran extended petitioners’
deadline for submitting information to be considered to May 14,
2004.
Petitioners’ section 6330 hearing was conducted by telephone
on March 31, 2004. On May 14, 2004, petitioners submitted to Ms.
Cochran a Form 656, Offer in Compromise, a Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, one letter explaining the offer amount, and three
letters setting out in detail petitioners’ position regarding the
offer-in-compromise. Petitioners’ letters included several
exhibits.
The Form 656 indicated that petitioners were seeking an
offer-in-compromise based on effective tax administration.
Petitioners offered to pay $346,258 to compromise their
outstanding tax liabilities for 1980 through 1996.8 At the
time of the section 6330 hearing, $750,740 had been assessed
against petitioners with respect to their 1980 through 1996
tax years.
On the Form 433-A, petitioners reported assets worth
$832,866 and outstanding liabilities of $56,359.
8 The details of petitioners’ 1986-88 and 1991-96 taxable
years are not in the record.
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Last modified: May 25, 2011