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scheduled for February 28, 2002, at the Appeals Office in
Washington, D.C. In response to petitioner’s request for
collection alternatives, Settlement Officer Craca asked
petitioner to submit income tax returns for taxable years 1997
through 2000 and “A completed Offer in Compromise package for
consideration.”
At petitioner’s request, the hearing originally scheduled
for February 28, 2002, was continued so as to provide petitioner
an opportunity to prepare and file the requested documents. In
March 2002, petitioner filed the requested income tax returns,
but he did not file an offer in compromise.
In a letter dated June 12, 2002, respondent informed
petitioner that his case was being transferred to the Appeals
Office in Houston, Texas (Houston Appeals Office), and that a new
Appeals officer would be assigned his case. The Houston Appeals
Office, in a letter dated July 17, 2002, requested that
petitioner file an income tax return for the 2001 taxable year
and a form concomitant to an offer in compromise. A hearing
under section 6330 was scheduled for August 14, 2002, with said
hearing to be conducted via telephone.
Petitioner did not submit to the Houston Appeals Office
either an offer in compromise or the requested tax return for
2001. He instead objected to having his case transferred,
because he wanted a face to face hearing under section 6330.
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