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By notice of trial setting, dated November 18, 1992, the
cases were again calendared for trial during the trial session in
Philadelphia, Pennsylvania, commencing on April 19, 1993. Again
the Court's Standing Pre-Trial Order was attached to the notice
of trial setting. On March 30, 1993, Attorney Riley filed
motions to continue the trial of the cases to permit petitioners
to avail themselves of the opportunity to submit offers in
compromise.2 After confirming that petitioners had submitted to
respondent such offers in compromise, the Court granted
petitioners' motions for continuance. On June 10, 1993,
respondent notified Attorney Riley that the offers in compromise
could not be processed due to missing information and because the
offers of $0 were unacceptable. The letter rejecting the Quinns'
offer indicates that no documentation supporting the innocent
spouse claim had been submitted with the offer, and thus
respondent was not able to consider that claim.
By notice of trial setting, dated July 1, 1993, the cases
were again calendared for trial during the Philadelphia,
Pennsylvania, trial session, commencing December 6, 1993. On
August 11, 1993, respondent sent a letter to Attorney Riley
suggesting a meeting on August 23, 1993; respondent followed the
letter with a telephone call on August 17, 1993. Attorney Riley
2 Generally, offers in compromise presuppose liability for
the tax. Such offers deal with collectability, a matter in which
this Court has no role.
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Last modified: May 25, 2011