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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.
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Last modified: May 25, 2011