- 13 -
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.
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: March 27, 2008