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and (b) the amount we could collect from your present
and future income as shown on page 4 of the Collection
Information Statement.
5. Petitioners’ Seventh Offer in Compromise
On November 20, 1995, respondent received a seventh offer in
compromise from petitioners. Respondent determined that
petitioners’ seventh offer could be processed and so advised
petitioners by letter dated January 9, 1996.
a. Investigation of the Seventh Offer
The investigator assigned to review and evaluate
petitioners’ offer was Revenue Officer Dewey Marine (Mr. Marine).
On May 9, 1996, Mr. Marine requested additional information from
petitioners in order to determine whether the amount of their
offer ($16,200) was adequate. Petitioners did not provide the
requested additional information within the specified time
period.
b. Rejection of the Seventh Offer
By letter dated May 31, 1996, respondent rejected
petitioners’ seventh offer because “you haven’t given us
enough information to determine if the amount of your offer is
adequate.”
c. Reconsideration of the Seventh Offer
By letter dated June 6, 1996, petitioner provided the
additional information previously requested and asked Mr. Marine
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