Carlos Londono - Page 3




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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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