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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.
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Last modified: May 25, 2011