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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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Last modified: May 25, 2011