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The Offer in Compromise provided, in relevant part, as
follows:
By submitting this offer, I/we understand and agree to
the following conditions:
* * * * * * *
(m) The offer is pending starting with the date an
authorized IRS official signs this form and accepts
my/our waiver of the statutory periods of limitation.
The offer remains pending until an authorized IRS
official accepts, rejects or acknowledges withdrawal of
the offer in writing. * * *
(n) The waiver and suspension of any statutory periods
of limitation for assessment and collection of the
amount of the tax liability described * * * [above],
continues to apply: while the offer is pending (see (m)
above) * * * and for one additional year beyond each of
the time periods identified in this paragraph.
On December 14, 1998, an authorized official signed the
Offer in Compromise on behalf of respondent and accepted the
waiver of the statutory period of limitations set forth in
paragraph (m) of the offer.
G. Abatement of the March 30, 1998 Employment Tax Assessment
On May 3, 1999, respondent abated the assessment made
against petitioner on March 30, 1998, for employment taxes and
additions to tax under section 6656. Respondent took this action
after discovering that the Forms 2504 executed by petitioner on
February 20, 1998, did not include the waiver paragraph required
by Notice 98-43, 1998-2 C.B. 207.4
4 Notice 98-43, 1998-2 C.B. 207, sets forth new procedures
(continued...)
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