- 4 -
(j) I/we understand that I/we remain responsible for
the full amount of the tax liability, unless and until
the IRS accepts the offer in writing and I/we have met
all the terms and conditions of the offer. The IRS
will not remove the original amount of the tax
liability from its records until I/we have met all the
terms of the offer.
D. Examination of Petitioner’s 1997 Return
Sometime after respondent accepted petitioner’s offer in
compromise, respondent commenced an examination of petitioner’s
income tax return for 1997. The examination culminated in the
issuance of the notice of deficiency in September 1999 from which
petitioner appealed to this Court.
E. Respondent’s Concession and Contention
Respondent concedes that the deficiency as determined in the
notice of deficiency is overstated and that the correct amount of
the deficiency is $709. In this regard, respondent contends that
the deficiency is equivalent to the difference between the
childcare credit claimed by petitioner on his return (and allowed
by respondent’s service center in processing petitioner’s return)
and the childcare credit to which petitioner is entitled, as
shown by the following:
Childcare credit claimed $960
Less: allowable childcare credit -251
Deficiency 709
4(...continued)
was the subject of an offer in compromise. The facts in the
present case do not, however, require that we decide this matter.
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Last modified: May 25, 2011