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OIC or until the OIC amount was paid in full, whichever was
longer (5-year compliance period); and (3) timely paying the
taxes reported due on their Federal income tax returns filed
during the 5-year compliance period. Specifically, paragraph (d)
on petitioners’ Form 656, Offer in Compromise, stated: “I/We
will comply with all provisions of the Internal Revenue Code
relating to filing my/our returns and paying my/our required
taxes for 5 years from the date the IRS accepts the offer”.
Under the express terms of the OIC, if petitioners failed to
meet any of the express conditions of the OIC, respondent had the
right to revoke the OIC and to attempt to collect from
petitioners the full amount of petitioners’ unpaid 1993 Federal
income taxes.
On May 7, 1998, petitioners paid to respondent the $10,000
OIC amount. Petitioners’ 5-year compliance period thus began
when respondent accepted the OIC on April 24, 1998.
During the 5-year compliance period, petitioners, among
other things, failed to pay estimated taxes, failed to timely
file their tax returns, and/or failed to timely pay taxes
reported due on their filed Federal income tax returns, as
follows:
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Last modified: March 27, 2008