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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 Petrohovich
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