Stuart Hult - Page 3




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          either entirely or largely to the imposition of the alternative             
          minimum tax.  See sec. 55.                                                  
               In an offer-in-compromise dated October 26, 2000 (the 2000             
          offer), petitioner proposed to satisfy his outstanding tax                  
          liabilities with an $8,256 cash offer, payable within 90 days               
          from the date the offer was accepted by respondent.  The 2000               
          offer, which was received by respondent on November 2, 2000, was            
          based upon “doubt as to collectability”.  Along with the 2000               
          offer, petitioner submitted various financial information and               
          documents in support of his claim that he had “insufficient                 
          assets and income to pay the full amount” of his outstanding tax            
          liabilities.                                                                
               The manner in which the 2000 offer was handled by respondent           
          is not entirely clear–-to say that it languished would be                   
          somewhat of an understatement.  According to petitioner, the 2000           
          offer was transferred from one of respondent’s offices to                   
          another, over and over again.  In the meantime, petitioner                  
          suffered the horror of being present at the World Trade Center              
          during the September 11, 2001, terrorist attack, apparently lost            
          his job, and moved from New York to Vermont, where he resided               
          when the petition was filed in this case.                                   
               In a letter dated June 16, 2003, petitioner was advised that           
          the 2000 offer was assigned to Revenue Officer Joseph Barry                 
          (Mr. Barry).  In the opening paragraph of the letter, Mr. Barry             







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