Allen Charles Schenkel - Page 4




                                        - 4 -                                         
          Officer Otterson gave petitioner a Form 433-A, Collection                   
          Information Statement for Individuals, and a Form 656, Offer in             
          Compromise.                                                                 
               On February 23, 2001, petitioner submitted an Offer in                 
          Compromise to respondent for 1988 through 1994 (first OIC).                 
          Under the reason for submission of the offer, petitioner checked            
          both boxes:  “Doubt as to Liability” and “Doubt as to                       
          Collectibility”.  Under the box for doubt as to liability, the              
          form stated that the taxpayer was required to include a detailed            
          explanation of the reasons why he believed he did not owe the               
          tax.  Petitioner, however, failed to do so.  Petitioner checked             
          the box for “Short Term Deferred Payment Offer (offered amount              
          paid in more than 90 days but within 24 months)”.  He listed the            
          monthly payment as $200 and the monthly payment date as “deducted           
          from paycheck”.  Petitioner left the line “Balance will be fully            
          paid on” blank.                                                             
               On March 5, 2001, Appeals Officer Otterson wrote to                    
          petitioner to inform him that the Form 656 he had provided to               
          petitioner was out of date and enclosed a current Form 656.                 
          Appeals Officer Otterson also asked petitioner for an explanation           
          of the $200 figure petitioner offered.                                      


               On April 2, 2001, petitioner submitted the new Form 656                
          (second OIC).  In the second OIC, petitioner listed the tax years           
          as 1989 through 1994.  Petitioner did not check any of the boxes            




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011