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included in the submission related to a different topic
designated by petitioners as such, the four topics being:
(1) A presentation of the facts and arguments related to the
hearing, including an explanation of the offer amount and medical
and retirement considerations; (2) a delay in the determination
and assessment of their liabilities due to the criminal
investigation of Hoyt; (3) effective tax administration; and
(4) tax-motivated interest under section 6621(c). The Form 656
was signed by each petitioner on June 14, 2004, and stated that
petitioners were making their offer-in-compromise on the grounds
of effective tax administration and doubt as to collectibility.
The Form 433-A was signed by each petitioner on June 14, 2004,
and reported that petitioners owned the following assets with a
current value (net of reported liabilities) of $124,038:3
Checking account $933
Money market account 576
IRAs1:
Vanguard 25,529
Zurich 31,161 56,690
Stock of GE/Motorola 8,165
Vehicles:
Ford Ranger 7,085
Less loan balance 10,997
(3,912)
Mercury Grand Marquis 4,920 1,008
3 Form 433-A states that each asset reported on the form
should be valued at its “Current value”, defined on the form as
“the amount you could sell the asset for today”.
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Last modified: November 10, 2007