Bernard A. Kansky - Page 7

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                  On July 22, 2004, respondent received from petitioner Form                            
            656, Offer in Compromise, and Form 433-A, but no Form 433-B.  On                            
            the Form 656, petitioner checked boxes indicating that he was                               
            submitting his offer-in-compromise on the grounds of doubt as to                            
            liability, doubt as to collectibility, and effective tax                                    
            administration.  He offered “$12,500 * * * to be applied first to                           
            pay’ts to my Social Security Account” in compromise of tax                                  
            liabilities totaling approximately $115,000 (including accrued                              
            interest).  Petitioner altered the standard terms of the Form 656                           
            so as to eliminate the statement that he was signing under                                  
            penalties of perjury.  As the basis for his offer-in-compromise,                            
            petitioner alleged that respondent’s revenue agents had engaged                             
            in “ministerial and managerial misconduct” by failing to review                             
            more promptly the boxes of documents he had submitted on November                           
            12, 1992, in response to the summons.  He challenged his                                    
            underlying tax liabilities for 1987 through 1991.                                           
                  Petitioner also altered the standard terms of the Form 433-A                          
            so as to eliminate the statement that he was signing under                                  
            penalties of perjury.  On the Form 433-A, petitioner failed to                              
            disclose his ownership interest in certain real estate.                                     
                  After evaluating petitioner’s offer-in-compromise and Form                            
            433-A, by letter dated September 30, 2004, the settlement officer                           
            requested additional information from petitioner, including a                               
            Form 433-B for petitioner’s business, a copy of petitioner’s 2003                           






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