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documentation verifying the monthly expenses claimed on Form 433-
A. Pursuant to petitioners’ requests, respondent, on several
occasions, extended the time to submit the substantiating
documentation. On April 20, 2005, respondent notified
petitioners that if they failed to provide the requested
documentation by April 30, 2005, the offer-in-compromise would be
rejected. Petitioners failed to provide the documentation by
April 30, 2005, and respondent returned petitioners’ offer-in-
compromise for failure to provide verification of claimed
expenses.5
E. Notice of Federal Tax Lien Filing of May 13, 2005
Petitioners failed to pay their income tax liabilities for
the years at issue after respondent gave notice and demanded
payment. On May 12, 2005, respondent filed a notice of Federal
tax lien with respect to the years at issue and on May 13, 2005,
mailed petitioners a Notice of Federal Tax Lien Filing and Notice
of Your Right to a Hearing Under IRC 6320 (second notice of
Federal tax lien).6 The second notice of Federal tax lien
indicated the “Type of Tax” owing was Form 1040, U.S. Individual
Income Tax Return, and listed unpaid balances of $5,713, $15,082,
$19,024, $37,485, $21,294, $13,124, $16,990, and $12,580, for
5 The Form 656 was returned on May 25, 2005.
6 Though the second notice in point of time, it was the
first notice as to all years except 1998.
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