BEGNER v. U.S.

No. 04-12976.

428 F.3d 998 (2005)

Alan I. BEGNER, Cory Begner, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

As Corrected September 2, 2005.


Attorney(s) appearing for the Case

Vivian D. Hoard, Marietta, GA, for the Begners.

Charles Bricken, Deborah K. Snyder, U.S. Dept. of Justice, App. Tax Div., Washington, DC, Amy Levin Weil, U.S. Atty., Mary Christine Roemer, Atlanta, GA, for U.S.

Before EDMONDSON, Chief Judge, and TJOFLAT and KRAVITCH, Circuit Judges.


TJOFLAT, Circuit Judge:

This case is about two taxpayers' Offer in Compromise (OIC), which is a contract between a taxpayer and the Internal Revenue Service in which the IRS agrees to accept an amount different from what the taxpayer owes in taxes. Specifically, the case is about whether the OIC permits the taxpayers to deduct amounts that they paid under a separate agreement that they had with the IRS. The taxpayers deducted the amount. The IRS objected, on the grounds...

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