Offer in Compromise Goes to Court
Taxpayer fails to solve IRS tax problems with Offer in Compromise
Joseph Dostal vs Commissioner T. C. Memo 2005-2647 November 16, 2005
Once again the Tax Court flames a taxpayer who challenges the rejection of an offer in compromise. The taxpayer made a timely application for a CDP. At the Collection Due Process hearing the taxpayer proposed an offer in compromise to settle his tax debt and solve his tax problems with the IRS. The taxpayers Form 433A and 433B clearly showed the taxpayer could full pay under the guidelines set out in the Internal Revenue Manual. The petitioner had $74,000 in IRA accounts and had income exceeding allowable expenses of $9,428 per month. No wonder the Tax Court agreed with the Offer Specialist. So what can we learn form this case? Click here
Joseph Dostal vs Commissioner T. C. Memo 2005-2647 November 16, 2005
Once again the Tax Court flames a taxpayer who challenges the rejection of an offer in compromise. The taxpayer made a timely application for a CDP. At the Collection Due Process hearing the taxpayer proposed an offer in compromise to settle his tax debt and solve his tax problems with the IRS. The taxpayers Form 433A and 433B clearly showed the taxpayer could full pay under the guidelines set out in the Internal Revenue Manual. The petitioner had $74,000 in IRA accounts and had income exceeding allowable expenses of $9,428 per month. No wonder the Tax Court agreed with the Offer Specialist. So what can we learn form this case? Click here







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