- 3 - Petitioners timely submitted a Form 12153, Request for a Collection Due Process Hearing. They also submitted an OIC in which they made a cash offer of $9,500 to compromise their 2000 and 2001 tax liabilities. The OIC was based on effective tax administration. Petitioners stated that Mr. O’Connor had been in a serious car accident that resulted in 9 weeks of hospitalization, including 5 weeks spent in a coma, and rendered him unable to work. Petitioners provided respondent with financial information in support of the OIC. Petitioners indicated they owned a residence with a fair market value of $85,000 that was subject to a $55,225 mortgage. Petitioners also indicated they owned a building with a fair market value of $149,000 that was unencumbered. Petitioners rented a portion of the building to an unrelated party and used the remainder for Mr. O’Connor’s computer and television repair business. After Mr. O’Connor was injured, however, the repair business generated little or no income. Petitioners’ case was assigned to a settlement officer, who conducted an administrative hearing. Petitioners did not seek to challenge the underlying tax liabilities during the hearing or offer collection alternatives aside from the OIC. After the hearing was concluded, respondent issued the notice of determination sustaining the lien filing and rejectingPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011