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petitioner and Mr. Moorhous that their offer in compromise would
be rejected with the right to seek reconsideration by
respondent’s Appeals office. Respondent did not send a written
rejection letter or notice of right to appeal to petitioner. At
that time, respondent had a policy of generally not accepting
offers in compromise from Federal employees. However, respondent
did not apply that policy to petitioner.3 Respondent
discontinued the policy effective July 18, 1997. IRS Litig.
Bull. 445 (October 1997).
On April 27, 1999, respondent sent to petitioner a Notice of
Intent To Levy and Notice of Your Right to a Hearing concerning
petitioner’s tax liability for 1989-92. The notice of intent to
levy stated that petitioner owed tax, penalty, and interest of
$17,909.98 for 1989, $10,266.83 for 1990, $9,980.32 for 1991, and
$19,400.89 for 1992, for a total of $57,558.02. On May 10, 1999,
petitioner requested a section 6330(b) hearing for tax years
1987-92. At the hearing, petitioner submitted her 1997 offer in
compromise and accompanying 1997 financial information. At the
hearing, the hearing officer stated that respondent erred in not
issuing a written rejection letter that advised petitioner of her
right to appeal the rejection of her 1997 offer in compromise to
respondent’s Office of Appeals. The hearing officer agreed to
3 Petitioner contends that respondent applied the policy to
petitioner in 1997. We decide this issue in the opinion.
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