David L. Samuel - Page 1

                                 T.C. Memo. 2007-312                                  

                               UNITED STATES TAX COURT                                

                           DAVID L. SAMUEL, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8431-05L.     Filed October 15, 2007.                       

                    P filed a petition for judicial review in response                
               to R’s determination to proceed with collection by lien                
               and/or levy of assessed income tax liabilities, plus                   
               additions to tax and interest, for 1996-2002.  R’s                     
               settlement officer rejected P’s offer-in-compromise                    
               because it was not a viable alternative to collection.                 
               The settlement officer, applying guidelines established                
               by the Internal Revenue Manual, determined that P                      
               should include in the amount of his offer-in-compromise                
               the value of certain “dissipated assets”, which,                       
               because of the dissipation, became unavailable for                     
               payment of P’s delinquent income tax obligation.  The                  
               settlement officer required this inclusion,                            
               notwithstanding that some of the assets had been used                  
               for proper purposes.                                                   

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Last modified: November 10, 2007