- 3 -
On September 3, 1999, petitioner submitted a Form 8857,
Request for Innocent Spouse Relief, requesting relief from joint
and several liability for the taxable years 1984, 1985, and 1986.
On April 24, 2001, petitioner submitted an amended Form 656,
Offer in Compromise, wherein he offered to compromise all income
tax liabilities, including any interest, penalties, additions to
tax, and additional amounts required by law, for the years 1986,
1987, and 1993 through 1999.2 Petitioner’s offer was to pay
$6,000 at a rate of $250 per month. Petitioner’s offer in
compromise was based on doubt as to collectibility, not on doubt
as to liability or the promotion of effective tax administration.
The Form 656 states that “Once the IRS accepts the offer in
writing, I/we have no right to contest, in court or otherwise,
the amount of the tax liability.” The form provides that the
offer in compromise may be withdrawn at any time before the
Commissioner accepts the offer. Petitioner was represented by
Carlton V. Phillips, Jr. (Mr. Phillips), during the offer in
compromise proceedings.
By letter dated May 7, 2001, D. Zukle (Mr. Zukle), an
Internal Revenue Service (IRS) manager, informed petitioner that
for 1986 and 1987 it was being proposed that he be granted
partial relief from joint and several liability under section
2Petitioner was married during 1986 and 1987, but was single
for the years 1993 through 1999.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011