Lawrence Jay Russ - Page 4




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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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