- 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 NextLast modified: March 27, 2008