- 8 -
after petitioners’ 1993 liability was fully satisfied. See infra
“E”.
At this time we are closing your case out of the
Problems Resolution Program and apologize for any
inconvenience we may have caused you.
Petitioners’ 1993 account remained in uncollectible status
until July 11, 1997.
D. Petitioners’ Efforts To Compromise Their 1993 Tax Liability
By virtue of section 7122(a), the Commissioner is authorized
to compromise a taxpayer’s tax liability. Pursuant to that
authority, the Commissioner has published directives regarding
offers in compromise.5 See Internal Revenue Manual (IRM), sec.
57(10)0 (Feb. 26, 1992) et seq. Form 656, Offer in Compromise,
is the form that respondent has designed for use by a taxpayer
who wishes to submit an offer in compromise.
When an offer in compromise is received from a taxpayer, a
determination is made by an offer technician whether the offer is
“processable”. IRM, sec. 57(10)9.1(1) (Feb. 26, 1992). An offer
that is processable is assigned to a collection officer,
typically a revenue officer, for investigation and evaluation.
An offer that is “unprocessable” is returned to the taxpayer.
5 We note that the enactment of sec. 7122(c), relating to
the evaluation of offers in compromise, because it applies to
offers in compromise submitted after July 22, 1998, does not
apply in this case. The same is true of the temporary
regulations published thereunder, which are applicable to offers
in compromise submitted on or after July 21, 1999, through July
19, 2002. See sec. 301.7122-1T(j), Temporary Proced. & Admin.
Regs., 64 Fed. Reg. 39027 (July 21, 1999).
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