- 10 - petitioner had failed to comply with her requests to verify his health claims, he did not qualify for an offer-in-compromise on the basis of effective tax administration. Accordingly, no viable collection alternative having been proposed, the settlement officer sustained respondent’s collection action. In his petition in docket No. 24528-04L, petitioner challenges respondent’s collection action. The petition states that “The only years which should be in question are the tax years 1987, 1990 and 1991” and adds: The only reason that the tax years 1987, 1990 and 1991 remain unpaid is that despite the taxpayer’s earmarking funds for the years due, the IRS nevertheless applied those payments instead, in such a haphazard manner so as to leave the oldest years ongoing and outstanding, thereby increasing the amount of compounding interest for even greater and extended periods of time. In his petition, petitioner alleges that he sustained an overall net loss for 1987 through 1991 and that loss carrybacks and carryforwards should eliminate any Federal income tax for these years. He claims to have already paid the IRS $27,000, representing 36 installment payments of $750 each. 5(...continued) sale value” of $508,880, reduced by a $123,096 encumbrance on the real estate and further reduced by 50 percent to reflect petitioner’s joint ownership with his wife.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011