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Year Amount
1994 $9,914.39
1995 6,738.88
1996 4,225.98
1997 4,990.48
1998 4,274.45
1999 4,433.95
On each of these returns, petitioner reported profits and losses
from a sole proprietorship, Innovative Marketing Group, on a
Schedule C, Profit or Loss From Business.
At the hearing, which was conducted by telephone,
petitioner’s counsel informed the Appeals officer that an offer
in compromise would be submitted. The Appeals officer agreed to
consider that position as a collection alternative to the levy.
Thereafter, the Appeals officer received from petitioner IRS Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, and petitioner’s first offer in
compromise (original offer in compromise). On the Form 433-A,
petitioner claimed a monthly transportation expense of $70 for a
vehicle, described as a 1986 Trooper. Before acting on the offer
in compromise, the Appeals officer forwarded the Form 433-A to a
revenue officer for verification. Petitioner satisfied that
verification through IRS Form 433-B, Collection Information
Statement for Businesses, which was sent to the revenue officer.
On the Form 433-B, petitioner also claimed expenses for the 1986
Trooper listed on the Form 433-A.
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Last modified: May 25, 2011