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collection due process) case, the offer in compromise would be
reviewed by the Office of Appeals rather than by the service
center.
On March 21, 2002, the Appeals officer sent to Zerjav a
letter stating that the offer in compromise had been reviewed but
that additional information was needed. Additional information
was submitted to the Appeals officer by Zerjav on April 23, 2002.
The Appeals officer reviewed the financial information submitted
by Zerjav on behalf of petitioner. She also independently
researched petitioner’s financial data and assets and concluded
that relevant information had not been disclosed by petitioner or
by Zerjav. Based on the information that she had obtained, the
Appeals officer determined that petitioner could pay her entire
1997 and 1998 income tax liabilities. The Appeals officer
considered petitioner’s reported income for 1999, 2000, and 2001.
The information relied on by the Appeals officer included
information about petitioner’s income for 2001, including a
withdrawal of more than $100,000 from an individual retirement
account and $40,000 in gross proceeds from the sale of real
property, and petitioner’s spouse’s income tax returns.
On June 11, 2002, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was sent to
petitioner. In addition to setting forth a determination that
the requirements of applicable law and administrative procedures
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Last modified: May 25, 2011