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BLONDHEIM v. COMMISSIONER

Docket No. 15549-05L.

92 T.C.M. 334 (2006)

T.C. Memo. 2006-216

Barry and Sherry Blondheim, v. Commissioner.

United States Tax Court.

October 10, 2006.

Attorney(s) appearing for the Case

Terri A. Merriam, Jaret R. Coles, Asher B. Bearman, and Jennifer A. Gellner, for petitioners;

Thomas N. Tomashek and Gregory M. Hahn, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6330(d) to review the determination of respondent's Office of Appeals (Appeals) sustaining a proposed levy relating to $298,003 of Federal income taxes owed by petitioners for 1981 through 1986.1 Petitioners argue that Appeals was required to accept their offer of $83,213 to compromise...

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