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From time to time, over the years, petitioner submitted
several other offers-in-compromise with respect to his
outstanding tax liabilities. On January 8, 1997, a Notice of
Federal Tax Lien was filed with respect to petitioner’s
outstanding 1981 Federal income tax liability, which at the time,
exceeded $260,000. On September 4, 1997, respondent accepted
petitioner’s $66,000 offer-in-compromise with respect to
petitioner’s 1981 income tax liability, but within months
petitioner defaulted on the payment plan that formed the basis
for that offer. Before making the 2004 offer, petitioner made
several other offers-in-compromise (the prior offers), each in an
amount substantially more than the 2004 offer. Respondent
rejected all of the prior offers upon the ground that the offers
did not adequately reflect petitioner’s ability to pay.
By letter dated May 25, 2004, respondent advised petitioner
that his outstanding tax liabilities were subject to collection
by levy. That letter also advised petitioner of his right to
request an administrative hearing in order to dispute the
proposed collection activity. Petitioner did so in a timely
fashion, and on July 8, 2004, during the course of the
administrative hearing, petitioner submitted the 2004 offer as a
collection alternative to the proposed levy with respect to his
outstanding tax liabilities. In the 2004 offer, petitioner
proposed to pay $1,000.
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Last modified: November 10, 2007