- 6 - On May 24, 1999, Revenue Agent R. Wygand, the revenue agent assigned to review the Offer in Compromise, spoke with Mr. Crowgey, who requested that the Offer in Compromise be reviewed by respondent’s counsel’s office. On June 16, 1999, a memorandum written by RC Stanley addressing the merits of the Offer in Compromise was sent to Group Manager Bill Stevens. On July 12, 1999, respondent issued a letter to petitioners notifying them of their right to appeal respondent’s determination that the Offer in Compromise should be rejected. On August 5, 1999, petitioners filed a protest of the rejection of the Offer in Compromise. Appeals Officer Barbara Petrohovich (AO Petrohovich) was assigned to review the Offer in Compromise. AO Petrohovich was also assigned to conduct a hearing pursuant to section 6330 regarding certain of petitioners’ tax years not here at issue. Between August 30, 1999, and January 3, 2000, AO Petrohovich discussed the dischargeability of taxes in petitioners’ bankruptcy proceeding with RC Stanley approximately three times. AO Petrohovich initiated the communications with RC Stanley, and all the communications occurred in RC Stanley’s office, which was in the same suite of offices as the office of AO PetrohovichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011