Amy H. O'Brien - Page 7

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          H. O’Brien 1999 Irrevocable Trust account at Fidelity                       
          Investments”.                                                               
               On September 28, 2001, respondent sent a letter rejecting              
          petitioner’s offer in compromise.  The letter explained that,               
          because the tax liabilities of approximately $13,000 could be               
          collected from the at least $175,000 remaining in the body of the           
          trust, the offer of $2,400 was not acceptable “due to the fact              
          that the taxpayer has the means to satisfy the entire debt at               
          this time.”                                                                 
               Petitioner submitted additional information supporting her             
          offer in compromise on October 4, 2001.  Specifically, she                  
          provided bank statements for the period of May 18 to August 19,             
          2001, a renewal lease for her apartment, a telephone bill, and a            
          utility bill.  Then, in a letter dated October 10, 2001,                    
          petitioner requested “further review” of respondent’s decision to           
          reject her offer, on grounds that respondent failed to address              
          “mitigating factors” weighing in petitioner’s favor.  In                    
          response, respondent sent a letter reiterating the reasons for              
          the rejection.  By a final letter dated October 18, 2001,                   
          petitioner’s representative continued to argue for acceptance of            
          her offer.                                                                  
               On May 9, 2002, respondent issued to petitioner the Notice             
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 sustaining use of the lien as an appropriate               






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