- 7 - 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 toPage: 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