Barry R. Downing and Mary A. Downing v. Commissioner

118 T.C. No. 2

UNITED STATES TAX COURT BARRY R. DOWNING AND MARY A. DOWNING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2217-00L. Filed January 7, 2002. Petitioners (Ps) filed a return for 1995 in which they correctly reported their tax liability but did not pay the tax owed. Ps included $5,000 and an offer in compromise in which they offered to pay that amount in full settlement of the $32,561 tax they owed. Respondent (R) misplaced Ps’ offer in compromise for about 1 year. R did not accept that offer in compromise or four similar offers in compromise made by Ps…