David W. Trout v. Commissioner

Draft #20 (to)

131 T.C. No. 16

UNITED STATES TAX COURT DAVID W. TROUT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5690-05L. Filed December 16, 2008. In 1997, P entered into an offer-in-compromise (OIC) covering tax years 1989, 1990, 1991, and 1993. The OIC included a term requiring P to timely file and pay his taxes for five years. P filed his 1996 tax return late, then failed to file 1998 and 1999 returns. P filed his 1998 taxes, showing a refund due, in November 2003, but failed to sign his 1999 return, which showed a liability of $164. In March 2004, R sent P a…