- 8 - Commissioner, 91 T.C. 1019, 1025 (1988); Brown v. Commissioner, 78 T.C. 215, 219 (1982). Petitioners argue that petitioners’ failure timely to file tax returns, to pay estimated taxes, and to pay the various additions to tax and penalties assessed against them during the 5-year compliance period did not constitute a material breach of the OIC and did not justify respondent’s revocation of the OIC and therefore that respondent’s Appeals Office abused its discretion in sustaining respondent’s notice of intent to levy. We disagree. The numerous instances of petitioners’ failure to keep their tax obligations current during the 5-year compliance period constitute, under any standard, a significant and material breach of the requirements of the OIC. We need not address different standards that, in other cases, might be considered and that might be applicable. See Ng v. Commissioner, T.C. Memo. 2007-8. Respondent mailed to petitioners a number of notices alerting petitioners to the potential for default on the OIC and giving petitioners opportunity to bring current their tax and other payments due. Although petitioners moved to a new address, petitioners failed to apprise respondent of their new address, and respondent cannot now be faulted for mailing the notices to the address shown on petitioners’ tax returns. Petitioners, not respondent,Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008