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25-Oct-2019 22:50

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The Baltics promptly requested a collection due process (CDP) hearing.

She also explained to them that, even though she herself couldn't consider the OIC-DATL as part of the CDP hearing, an Appeals officer within another part of the IRS would consider it and a revenue officer in yet a third part of the IRS would examine the Baltics' amended 1999 return in what is called an "audit reconsideration." The settlement officer then ended the CDP hearing, and sent the Baltics a notice in which she determined that collection by levy would be postponed until the IRS both decided whether to accept the OIC-DATL and finished its "audit reconsideration," but that the lien would be sustained. Section 6330(c)(2)(B) allows a taxpayer to challenge the existence or amount of his underlying tax liability if he neither received a notice of deficiency nor otherwise had an opportunity to dispute it. (Sustaining the lien protects the government's priority over other creditors.) The Baltics offered no other collection alternatives. The Baltics' first line of attack is that they should have been allowed to challenge their underlying liability because section 6330(c)(2)(B) --though it allows challenges to "the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency" --doesn't say that it allows such challenges "only if the person did not receive any statutory notice of deficiency."This parsing has no support in any caselaw, as the Baltics' counsel admitted at oral argument. The Baltics now argue that the settlement officer's refusal to consider the OIC-DATL herself,4 or at least to wait before issuing the notice of determination until the other parts of the IRS finished looking at the OIC-DATL and amended return, was an abuse of discretion. And we won't be creating any here: Congress used section 6330(c) --and only section 6330(c) --to describe how a CDP hearing would work. 2005-198, we wrote in a footnote that an OIC-DATL "would address the merits of the underlying liability. Section 6330 1 says that taxpayers like the Baltics can't challenge their "underlying tax liability." The main question in this case --which we've apparently never quite squarely answered --is whether their making an offer-in-compromise based on doubt as to liability (an OIC-DATL) is a challenge to the "underlying tax liability."Background In February 2003, the Commissioner sent the Baltics a notice of deficiency saying they owed over 0,000 in income tax and penalties for 1999.

The Baltics don't dispute that they received the notice, and don't dispute that they never filed a petition in this Court to challenge it.

Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability. Which is, of course, exactly what they could have challenged by filing a petition when they got their notice of deficiency. Adding a desire to wait for consideration of an OIC-DATL as well adds nothing to the argument: The settlement officer here was just heeding the exhortation of the applicable regulation to issue a notice of determination as expeditiously as possible.