- 4 -
Table 1: Unpaid Taxes by Year
Tax Year Tax Due
1998 $6,577.17
1999 11,003.93
2000 5,752.52
2001 6,053.45
2002 3,260.58
Total 32,647.65
In response to the notice of Federal tax lien Filing and
Your Right to a Hearing Under IRC 6320 sent to him on March 24,
2005, petitioner timely submitted a Form 12153, Request for a
Collection Due Process Hearing.
On September 15, 2005, after consulting with petitioner,
respondent consolidated the two appeals (the appeal of the
rejection of the OIC and the appeal of the Federal tax lien
filing) with one Appeals Officer (AO). The AO scheduled a
hearing with petitioner for October 5, 2005.
Before the hearing, the AO analyzed petitioner’s financial
situation and determined what expenses were allowable under
Internal Revenue Manual (IRM) guidelines. Petitioner’s central
complaint with the rejection of his OIC was the exclusion of his
monthly credit card payments from the expenses allowed in
computing his income available to pay his outstanding tax
liabilities.
At the face-to-face conference between petitioner and the AO
on October 5, 2005, petitioner sought approval of his OIC and did
not challenge the underlying tax liabilities. The AO explained
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: March 27, 2008