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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 make
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Last modified: May 25, 2011