David and Monika Zisskind - Page 4
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information provided by petitioners unsatisfactory and returned
the offer-in-compromise forms to petitioners on April 27, 2004.
On April 29, 2004, respondent sent petitioners a Notice of
Federal Tax Lien and Your Right to a Hearing Under IRC 6320
(notice of Federal tax lien) for their outstanding tax liability
for 1999. At the time respondent issued the notice of Federal
tax lien, petitioners owed $29,414, including penalties and
On May 18, 2004, petitioners submitted to respondent a Form
12153, Request for a Collection Due Process Hearing (request for
a section 6330 hearing). Petitioners requested that an offer-in-
compromise or an installment agreement be entered into. However,
petitioners did not provide a Form 656, a Form 433-A, or an
installment agreement request.2
On June 17, 2004, Settlement Officer Maria Russo (Ms. Russo)
of respondent’s Boston Appeals Office was assigned to
petitioners’ case. On September 28, 2004, Timothy J. Burke (Mr.
Burke), petitioners’ attorney, telephoned Ms. Russo to discuss
petitioners’ request for a section 6330 hearing. On October 21,
2 At various times during their sec. 6330 hearing and
afterwards, petitioners requested an offer-in-compromise or an
installment agreement. In the notice of determination,
respondent determined that petitioners abandoned their request
for an offer-in-compromise and did not provide adequate financial
information so that an installment agreement could be considered.
Petitioners do not dispute this determination in their petition
or on brief, and we do not discuss the offer-in-compromise and
the installment agreement further.
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Last modified: November 10, 2007