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Respondent’s failure to send petitioner a written rejection
of her 1997 offer in compromise did not deprive her of any
administrative appeal rights. The hearing officer for
petitioner’s section 6330 hearing stated that respondent erred in
not issuing a written rejection letter that advised petitioner of
the right to administratively appeal that rejection. Respondent
contends on brief that that statement by the hearing officer was
wrong because, in 1997, taxpayers had no appeal rights concerning
rejected offers in compromise. Petitioner does not dispute
respondent’s statement in this regard and offers no contrary
authority. We conclude that petitioner was not prejudiced by the
hearing officer’s failure to consider her offer in compromise
based on 1997 financial information or by respondent’s failure to
give her written notice in 1997 that her 1997 offer in compromise
had been rejected. See Rodriguez v. Commissioner, T.C. Memo.
2003-153.
Petitioner contends that respondent’s refusal to consider
her offer in compromise in 1997 was based on respondent’s policy
then in effect of generally not accepting offers in compromise
from Federal employees. We disagree. There is no evidence to
support her contention, and there is credible evidence showing
that respondent did not apply that policy to her.
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Last modified: May 25, 2011