William C. and Elaine Gaskins - Page 4

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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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