Francis A. Morlino - Page 3

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          government and the taxpayer that an Offer in Compromise be                  
          entered into.”                                                              
               Petitioner raised no other issue on the Form 12153 or during           
          the subsequent hearing accorded him.                                        
               On or about November 20, 2002, petitioner submitted an offer           
          in compromise with respect to the unpaid tax.  That offer in                
          compromise was rejected on January 15, 2003.                                
               On or about May 6, 2003, an Appeals Office official,                   
          settlement officer Eugene O’Shea, was assigned to petitioner’s              
          case.                                                                       
               By letter dated July 23, 2003, addressed to petitioner, Mr.            
          O’Shea introduced himself to petitioner, scheduled a meeting with           
          him for August 5, 2003, acknowledged petitioner’s request for an            
          offer in compromise, and, in connection with that request,                  
          provided him with a questionnaire and an IRS Form 656, Offer in             
          Compromise (the questionnaire and the offer form, respectively).            
          The letter instructed petitioner that he was to complete and                
          submit the questionnaire and offer form to Mr. O’Shea by August             
          5, 2003, even if the meeting scheduled for that date were to be             
          postponed.                                                                  
               On August 4, 2003, at Mr. Burke’s request, Mr. O’Shea moved            
          the August 5, 2003, meeting to August 18, 2003, and gave                    
          petitioner until that date, but no later, to provide the                    
          requested information and submit the offer form.                            






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