- 4 - final notice to petitioners in respect of their outstanding liability for 2002, which, at that time, was approximately $1,407 (without regard to statutory accruals of interest and penalty). Administrative Developments Petitioners timely filed with respondent a Form 12153, Request for a Collection Due Process Hearing. In the Form 12153, petitioners focused only on the existence or amount of their underlying liability. By letter dated August 16, 2006, respondent’s settlement officer advised petitioners that, inter alia: For me to consider alternative collection methods such as an installment agreement or offer in compromise, you must provide any items listed below. In addition, you must have filed all federal tax returns required to be filed. The “items listed below” included a completed Collection Information Statement (Form 433-A for individuals and/or Form 433-B for businesses) and signed income tax returns for 2003, 2004, and 2005. Regarding the latter, the settlement officer stated that “Our records indicate they have not been filed”. The settlement officer subsequently conducted a telephonic conference with Mrs. Manousos. Petitioners never submitted a Collection Information Statement or proposed a specific collection alternative, nor did petitioners file all of the requested returns during the time that their case was pending before respondent’s Appeals Office.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007