Claude E. and Dana L. Salazar - Page 13




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               On February 22, 2006, respondent issued a Final Notice of              
          Intent to Levy and Notice of Your Right to a Hearing with respect           
          to Mr. Salazar’s employment tax liabilities.4  In response, Mr.             
          Salazar submitted a second Form 12153 with respect to the                   
          proposed collection action on the employment tax liabilities.               
          The new request for collection review was assigned to Appeals               
          Settlement Officer Thomas Conley.  In his initial correspondence            
          with Mr. Conley, Mr. Salazar indicated that he did not intend to            
          submit a new offer-in-compromise but instead sought                         
          reconsideration of petitioners’ original offer-in-compromise of             
          $9,024.25.  Mr. Salazar also attempted to challenge the                     
          assessment of penalties and interest during the pendency of                 
          petitioners’ bankruptcy as well as the manner in which respondent           
          applied the bankruptcy proceeds.                                            
               On May 17, 2006, petitioners had an in-person hearing with             
          Mr. Conley.  On June 20, 2006, Mr. Salazar submitted a new offer-           
          in-compromise.  The basis of the new offer-in-compromise was                
          again doubt as to collectibility, and the new offer included                
          updated financial information.  Mr. Salazar offered to compromise           
          petitioners’ then-outstanding income and employment tax                     
          liabilities for $19,547.13.  By this time, Mrs. Salazar was                 
          working as an attorney and Mr. Salazar as a manager of a                    


               4 Respondent’s notice of intent to levy did not include the            
          periods ending Dec. 31, 1998, or Mar. 31, 1999.                             






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