- 6 - 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 “AmyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011