Michael Keller - Page 6

                                        - 6 -                                         
          claim any of the Hoyt-related expenses claimed on his returns;              
          (2) agreed that the higher rate of interest applicable to tax-              
          motivated transactions will apply; and (3) waived any claim for             
          the abatement of interest.  Petitioner did not accept the                   
          settlement offer.                                                           
               On March 10, 2003, respondent sent petitioner a Final Notice           
          of Intent to Levy and Notice of Your Right to a Hearing relating            
          to 1991, 1992, and 1993.  On April 8, 2003, petitioner submitted            
          a Form 12153, Request for a Collection Due Process Hearing.                 
          Petitioner indicated he would pursue offers-in-compromise based             
          on doubt as to collectibility and effective tax administration              
          and would provide financial information upon request.                       
               On January 21, 2004, a section 6330 hearing was held by                
          phone between Settlement Officer Kathleen Lee (Ms. Lee) and Terri           
          A. Merriam (Ms. Merriam), petitioner’s attorney.  Ms. Merriam               
          indicated that petitioner would most likely be able to pay the              
          tax in full, and thus he wished to pursue only an effective tax             
          administration offer-in-compromise.  However, Ms. Merriam did not           
          provide Ms. Lee with Form 656, Offer in Compromise, or with Form            
          433-A, Collection Information Statement for Wage Earners and                
          Self-Employed Individuals.                                                  
               On February 4, 2004, Ms. Merriam sent Ms. Lee a letter                 
          indicating that petitioner had not yet completed a Form 433-A,              
          but one would be obtained “shortly”.  Because petitioner would              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011