Amy H. O'Brien - Page 6

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          previous installment plan, because information submitted by                 
          petitioner showed monthly expenses in excess of income, and                 
          because the suggested monthly payments would be insufficient to             
          pay her liabilities within the statute of limitations for                   
          collection.  After petitioner received this letter, her                     
          representative apparently contacted respondent by telephone and             
          discussed possible use of an offer in compromise.  Respondent               
          then sent a letter dated May 1, 2001, confirming the telephone              
          conversation and requesting completion of the enclosed Form 656,            
          Offer in Compromise, and Form 433-A, Collection Information                 
          Statement for Wage Earners and Self-Employed Individuals.                   
               Respondent received the Form 656 and Form 433-A submitted by           
          petitioner on September 4, 2001.  The Form 656 asked petitioner             
          to select as the reason for the offer either doubt as to                    
          liability, doubt as to collectibility, or effective tax                     
          administration.  Petitioner checked effective tax administration,           
          which the form explained as meaning “I owe this amount and have             
          sufficient assets to pay the full amount, but due to my                     
          exceptional circumstances, requiring full payment would cause an            
          economic hardship or would be unfair or inequitable.”  Petitioner           
          proposed to pay a total of $2,400 by remitting $240 for the first           
          month and $180 per month for each of the next 12 months.  The               
          Form 656 indicated that the source of the funds would be the “Amy           








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