- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011