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for redetermination. Petitioner and respondent executed a
stipulated decision which was entered by the Court.2
Respondent assessed a deficiency for 1999 in accordance with
the stipulated decision. In addition, respondent assessed unpaid
taxes for 1998, 2000, 2001, and 2002 based on the balance due
returns petitioner filed for those years, as well as interest and
additions to tax for late filing.
Petitioner submitted an offer-in-compromise (OIC) with
respect to his tax liabilities for the years in issue.
Petitioner offered $5,320, paid over 24 months, to settle an
aggregate liability that exceeded $32,000 for the 5 tax years
(not including interest and additions to tax). Respondent
considered the OIC, determined that petitioner could pay the
entire liability over time, and rejected the OIC. Petitioner
requested an administrative review of the rejection of his OIC.
Respondent filed a notice of Federal tax lien for the years
in issue in Ventura County, California, on March 17, 2005. The
notice listed petitioner’s unpaid balance as:
2 Docket No. 2721-02, stipulated decision entered Jan. 9,
2003.
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