John E. and Sandra L. West - Page 3




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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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