- 2 - This proceeding arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) issued to petitioners on April 5, 2006. Pursuant to sections 6320(c) and 6330(d), petitioners seek review of respondent’s determination sustaining the filing of a notice of Federal tax lien against them. The issue for decision is whether respondent abused his discretion in rejecting an offer-in- compromise (OIC) that petitioners submitted for the taxable years 2000 and 2001. Background The record consists of the declaration of respondent’s settlement officer, a copy of respondent’s administrative file, and the testimony of petitioner Anthony O’Connor. At the time the petition was filed, petitioners resided in Citrus Springs, Florida. Petitioners have a daughter who was 9 years old at the time of trial. Respondent made assessments against petitioners for the taxable years 2000 and 2001 for tax and related interest. Respondent also assessed an accuracy-related penalty for the taxable year 2000. Respondent filed a notice of Federal tax lien and sent petitioners a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011