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Lepordo submitted an offer-in-compromise that was rejected on
February 9, 2004. Mr. Lepordo subsequently passed away on
February 24, 2004. Thereafter, petitioner submitted an offer-in-
compromise for $1,500 that was rejected on March 25, 2005.
Apparently, petitioner’s second offer-in-compromise for $5,060
was never received, and the IRS cannot find its related
paperwork.
After petitioner’s offers-in-compromise were rejected or
went unanswered, petitioner’s deceased spouse’s tax preparer
advised her to seek innocent spouse relief. Petitioner filed
Forms 8857 on May 18, 2005, seeking equitable relief under
section 6015(f) for 1996 and 1998 through 2002.
On October 12, 2005, respondent issued his preliminary
determinations. Respondent denied relief for 1996 because
petitioner’s request for relief was untimely since it was
received more than 2 years after the first collection activity.
The first collection activity, a notice of intent to levy,
occurred April 21, 2003, and petitioner’s request was received on
May 18, 2005. Respondent denied petitioner’s requests for the
years 1998, 2001, and 2002 because she did not satisfy the
criteria for relief. Evidently, the preliminary determination(s)
for 1999 and 2000, which also cannot be found, denied relief for
1999 and 2000 for the same reasons.
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Last modified: March 27, 2008