- 7 - his estimated tax payments for 2001 establish petitioner’s failure to be in current compliance with his Federal income tax liabilities and support respondent’s determination to disapprove of petitioner’s offer in compromise. Relying on respondent’s temporary regulations under section 7122, petitioner asserts that respondent’s Appeals officer, prior to rejecting petitioner’s offer in compromise, failed to have her proposed rejection of the offer in compromise reviewed by an “independent reviewer”. See sec. 301.7122-1T(e)(2), Temporary Proced. & Admin. Regs., 64 Fed. Reg. 39026 (July 21, 1999). Petitioner apparently believes that respondent’s Appeals officer manager who reviewed the Appeals officer’s determination to reject petitioner’s offer in compromise does not qualify as an “independent” reviewer under the above statute and regulation. To the contrary, in the context of a collection hearing before respondent’s Appeals Office, the prescribed independent administrative review of a proposed rejection of an offer in compromise generally is to be performed by an Appeals manager, which in this case occurred on August 7, 2001. 4 Administration, Internal Revenue Manual (CCH), sec. 8.7.2.3.5(3)(f), at 27,282 (Nov. 13, 2001), promulgated under the legislative authority of sec. 7122(d).1 1 4 Administration, Internal Revenue Manual (CCH), sec. 8.7.2.3.5(3)(f), at 27,282 (Nov. 13, 2001), among other things, (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011