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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petitioner was out of date and enclosed a current Form 656.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
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Last modified: May 25, 2011