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Appeals (Appeals) sustaining a proposed levy related to
petitioners’ 1989 Federal income tax year.2 Petitioners argue
the proposed levy is improper because, they state, Appeals was
required to accept their offer of $90,258 to compromise what they
estimate is their $260,143 Federal income tax liability
(inclusive of additions to tax, penalties, and interest) for 1987
through 1998.3 We decide whether Appeals abused its discretion
in rejecting that offer.4 We hold it did not.
FINDINGS OF FACT
The parties filed with the Court stipulations of fact and
accompanying exhibits. The stipulated facts are found
accordingly. When the petition was filed, petitioners resided in
Kennewick, Washington.
Beginning in 1987, petitioners’ Federal income tax returns
claimed losses and credits from their investment in partnerships
organized and operated by Walter J. Hoyt III (Hoyt). One of
2 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Dollar amounts
are rounded.
3 Petitioners submitted to respondent Form 656, Offer in
Compromise, indicating that they were offering to compromise
their tax liability for 1987 through 1996. Petitioners included
with that submission a letter in which they stated that they
wished to compromise their tax liability for 1987 through 1998.
We read petitioners’ offer to include 1987 through 1998.
4 While the petition references sec. 6621(c) interest,
respondent did not determine that petitioners were liable for
such interest in the referenced years. We express no opinion on
the subject.
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