Debra L. Streck and Donald W. Streck - Page 9

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          Sower's signature appears under this preprinted statement on each           
          form.  By signing the Forms 656, Mr. Sower accepted petitioners'            
          waiver of the statutory period of limitations.  By signing the              
          Forms 656 in this manner, Mr. Sower did not accept petitioners'             
          offers.                                                                     
               Form 656 makes it clear that Mr. Sower's signature was not             
          an acceptance of petitioners' offer in compromise.  Clause (8) of           
          Form 656 states:                                                            

               The taxpayer-proponents agree to the waiver and                        
               suspension of any statutory periods of limitations for                 
               assessment and collection of the tax liability                         
               described in paragraph (1) while the offer is pending,                 
               during the time any amount offered remains unpaid and                  
               for one (1) year after the satisfaction of the terms of                
               the offer.  The offer shall be deemed pending from the                 
               date an authorized official of the Internal Revenue                    
               Service accepts taxpayer-proponents' waiver of the                     
               statutory periods of limitation and shall remain                       
               pending until an authorized official of the Internal                   
               Revenue Service formally, in writing, accepts, rejects                 
               or withdraws the offer.  * * *                                         

          Clause (10) of Form 656 states that "It is understood that this             
          offer will be considered and acted upon in due course and that it           
          does not relieve the taxpayers from the liability sought to be              
          compromised unless and until the offer is accepted in writing by            
          the Commissioner or a delegated official, and there has been full           
          compliance with the terms of the offer."  (Emphasis added.)                 
          Petitioners signed the Forms 656 agreeing to these terms.10                 

               10We note that if petitioners believed that Mr. Sower's                
                                                             (continued...)           




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