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efficient collection of taxes with the concern that the proposed
levy be no more intrusive than necessary. As to the former
conclusion, the notice states:
Taxpayers challenged the proposed enforcement
collection action by levy.
Taxpayers submitted an Offer in Compromise, Doubt as to
Collectibility and Effective Tax Administration, in the
amount of $11,552.00 during the CDP proceedings. The
OIC was not an acceptable collection alternative and
was rejected.
Taxpayers did not disclose all assets on the Collection
Information Statements attached to the offer. They did
not disclose assets which constituted about 25% of
their net realizable equity. By not disclosing their
complete financial status, this Appeals Officer is
concerned about their good faith effort to resolve this
matter. They were not forthcoming in establishing
their financial status.
This Appeals Officer concluded the offer should not be
accepted under doubt as to collectibility because
taxpayers have sufficient assets to pay the assessed
liability. Further, the offer should not be accepted
under effective tax administration as it would
undermine compliance by taxpayers with the tax laws.
Taxpayers included in the offer years that have
unresolved TEFRA issues, thus the liability has not
been assessed. During the Collection Due Process
proceedings taxpayers did not resolve the years with
TEFRA issues by entering into settlement agreements.
Taxpayers did not propose any other acceptable
collection alternatives. Taxpayers declined to pay the
outstanding liability.
The proposed collection enforcement action by levy is
valid and appropriate.
The notice further states:
The proposed collection action by levy balances the
need for the efficient collection of taxes with the
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Last modified: November 10, 2007