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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 rejecting
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Last modified: May 25, 2011