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to a Hearing. On behalf of petitioner, Zerjav submitted a
Request for Collection Due Process Hearing, Form 12153. On
November 7, 2001, petitioner signed a Form 656, Offer in
Compromise, proposing to compromise her 1997 and 1998 Federal
income tax liabilities for $100. The offer in compromise, with
supporting information, was submitted to the Brookhaven Service
Center in Holtsville, New York.
On February 8, 2002, an Appeals officer sent to petitioner a
letter advising her that the hearing that she had requested was
tentatively scheduled for February 26, 2002, but that another
time for a hearing could be arranged. The letter stated:
If you want us to consider any collection alternatives,
such as an installment agreement or offer-in-
compromise, please complete the enclosed financial
statements. These may include Form 433-A, Collection
Information Statement for Individuals and/or
Form 433-B, Collection Information Statement for
Businesses. Provide complete verification of your
income and expenses. We must be able to review this
information to determine that collection alternatives
are possible.
Zerjav responded to the Appeals officer’s February 8, 2002,
letter. Zerjav stated that an offer in compromise had been
submitted to the Brookhaven Service Center, and he requested that
the hearing be rescheduled “for after the valuation currently
being held with the Brookhaven Service Center.” On February 14,
2002, the Appeals officer explained in a telephone conference
with Zerjav that, because this was a “CDP” (section 6330
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Last modified: May 25, 2011