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respect to the intended collection action or possible alternative
means of collection. See Rule 331(b)(4); Goza v. Commissioner,
114 T.C. at 183. Even if petitioners had not conceded this
issue, petitioners’ factual allegations and arguments would not
establish that the Appeals officer abused his discretion in
sustaining respondent’s levy.
We shall not consider an August 8, 2002, letter (the
settlement letter) attached to petitioners’ reply brief in which
petitioners offered to settle all tax, interest, and penalties
for $100,000 to be paid within 90 days of acceptance of their
offer; that letter was never properly introduced into evidence,
as required by Rule 143. See also Kronish v. Commissioner, 90
T.C. 684, 695-696 (1988).
Even if the settlement letter had been properly introduced,
we would not consider it a valid offer in compromise. Taxpayers
who wish to propose an offer in compromise must submit a Form
656, Offer in Compromise, which requests financial information
from the taxpayer so that the IRS can determine whether the offer
should be accepted. See sec. 7122(c); see also 2 Administration,
Internal Revenue Manual (CCH), sec. 5.8.1.3(a).
Petitioners’ offer was invalid because they did not submit a
Form 656 or otherwise describe their income, assets, and other
financial information required by Form 656 in order for
respondent to evaluate whether the offer should be accepted.
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