- 10 - 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 thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007