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agents in Chicago.” Mr. Orum proposed to Settlement Officer
Susan L. Vuicich (Ms. Vuicich) that petitioners be permitted to
satisfy the 1998 and 1999 tax liabilities through another
installment agreement.
On or about February 7, 2002, petitioners submitted a Form
656, Offer in Compromise, and Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals.
On June 20, 2002, respondent sent Mr. Orum a letter
scheduling an equivalent hearing for 1998 and a section 6330
hearing for 1999 by telephone for July 23, 2002, and requesting
Mrs. Orum’s signature on the hearing request. The June 20, 2002,
letter also stated:
You are not entitled to a Collection Due Process
Hearing for 1998. According to our records a final notice
was sent to you by certified mail for this year on June 22,
2000.[2] However, you are entitled to an equivalent hearing.
I have enclosed Publication 1660, which explains an
equivalent hearing.
You marked Form 12153 appealing the filed Notice of
Federal Tax Lien. You are not entitled to a hearing on this
issue as our records show no lien has been filed.
You subsequently submitted an offer in compromise under
doubt as to collectibility and Effective Tax Administration.
I have returned this offer to you under separate cover. You
can resubmit your offer once you are current with filing
your tax returns. However, let me explain why your offer
would not be accepted. It appears that based upon the
financial information you provided you have the ability to
2 We note that the Form 4340, Certificate of Assessments,
Payments, And Other Specified Matters, and the ACS LT11 Certified
Mail List report that this notice was sent on June 23, 2000.
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