- 2 -
Held: R’s rejection of P’s offer-in-compromise
was an abuse of discretion, and this case will be
remanded to the IRS Appeals Office so that P may make a
revised offer reflecting a reduced amount of dissipated
assets.
William A. Neilson and Douglas L. Salzer, for petitioner.
Linda A. Neal, for respondent.
MEMORANDUM OPINION
NIMS, Judge: This case 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. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the years in issue as amended, and all
Rule references are to the Tax Court Rules of Practice and
Procedure. The issue for decision is whether respondent’s
rejection of petitioner’s offer-in-compromise was an abuse of
discretion.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulations of the
parties, with accompanying exhibits, are incorporated herein by
this reference. At the time he filed the petition, petitioner
resided in Louisiana.
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