- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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