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during the entire time that AO Petrohovich was assigned to review
petitioners’ protest of the IRS’s rejection of the Offer in
Compromise.
On December 15, 1999, AO Petrohovich held a conference with
Mr. Crowgey. She informed Mr. Crowgey that she disagreed with
him regarding the dischargeability of petitioners’ income taxes
for tax years 1991, 1992, and 1993.
AO Petrohovich determined that she did not see substantial
hazards with regard to respondent’s position rejecting the Offer
in Compromise. She came to this conclusion based on a review of
RC Stanley’s June 16, 1999, memorandum to Group Manager Stevens
that was contained in the collection file, the discussions with
RC Stanley regarding the substance of that memorandum, and her
own review of the court cases referenced by Mr. Crowgey.
On January 6, 2000, Mr. Crowgey contacted Appeals Chief
George Gretes with regard to the handling of petitioners’ case.
Mr. Crowgey told Appeals Chief Gretes that it was his belief that
RC Stanley was an advocate for the Collection Division and that
he wanted someone else in respondent’s counsel’s office to review
this matter.
On February 24, 2000, Appeals Chief Gretes sent a letter to
Mr. Crowgey that had been reviewed by AO Petrohovich. Prior to
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