- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioners Martin Smith (Smith) and Sharon Smith petitioned the Court under section 6330(d) to review the determination of respondent’s Office of Appeals (Appeals) sustaining a proposed levy related to petitioners’ assessed Federal income tax liability (inclusive of additions to tax, penalties, and interest) for 1984, 1985, 1986, and 1991; that liability totaled $79,461. Petitioners argue that the proposed levy is improper because, they argue, Appeals was required to accept their offer to pay $11,552 to compromise their assessed and unassessed Federal income tax liability (inclusive of additions to tax, penalties, and interest) for 1984 through 1996; petitioners estimate that liability to total $265,023. We decide whether Appeals abused its discretion in rejecting petitioners’ offer. We hold it did not.2 2 Petitioners also dispute a determination by Appeals concerning their liability for increased interest under sec. 6621(c). As to this dispute, the parties agreed to be bound by a final decision in Ertz v. Commissioner, docket No. 20336-04L, which involved a similar issue. On Jan. 24, 2007, the Court held in Ertz v. Commissioner, T.C. Memo. 2007-15, that the Court lacks jurisdiction to decide the issue to which the parties agreed to be bound. On the basis of Ertz v. Commissioner, supra, we shall dismiss for lack of jurisdiction the portion of this case that concerns petitioners’ liability for increased interest under sec. 6621(c).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007