- 3 - Under petitioner’s offer in compromise, petitioner offered to pay a total of only $3,741 in 19 monthly installments of $200 each, in full compromise of petitioner’s cumulative total outstanding Federal income tax liabilities for 1990 through 1999 of $91,120. In a number of significant respects, petitioner’s offer in compromise is incomplete. In late 2000, petitioner filed with respondent his delinquent Federal income tax returns for 1993 through 1999. Three of petitioner’s above-mentioned Federal income tax returns were not filed until after respondent had issued audit summonses with regard thereto. On November 9, 2000, respondent’s Appeals officer sent a letter to petitioner’s representative offering to meet regarding the proposed levy and offer in compromise. Petitioner’s representative declined to meet with respondent’s Appeals officer, but on November 29, 2000, petitioner’s representative did call respondent’s Appeals officer and discussed with her petitioner’s offer in compromise. On February 20, 2001, respondent’s Appeals officer forwarded petitioner’s offer in compromise to an “offer group” within respondent’s organization that reviews offers in compromise. On July 3, 2001, after reviewing financial information that petitioner had submitted, respondent’s offer in compromise specialist calculated that petitioner likely could afford to makePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011