Carolyn D. Ramirez - Page 7

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              MUST be presented to a retail clerk at a post office.                   
              Postage that is affixed to the return mail may be used                  
              for re-mailing the item.                                                
                                                                                     
          On the notice from the Postal Service was the following                     
          handwritten message from a Postal Service employee:  “You dropped           
          a large priority envelope in the drop box - it was returned, but            
          I cancelled the stamps for you and sent it on - to avoid further            
          delay.”  The notation “8-2” is handwritten on the envelope in               
          which petitioner mailed her materials to the Appeals officer.               
               Petitioner timely filed a petition with this Court under               
          section 6330(d).  After petitioner’s case was set for trial, in             
          the words of the stipulation of the parties, “As a courtesy to              
          Petitioner, Respondent’s counsel forwarded * * * [her file] to an           
          Offer Specialist to review in an effort to determine if the case            
          could possibly be settled by way of an offer in compromise.”  The           
          settlement negotiations were unsuccessful.                                  
               The underlying tax liability is not in dispute in this case.           
          Following a Stipulation of Settled Issues filed with the Court on           
          June 9, 2003, the sole issue to be decided is whether the Appeals           
          officer properly considered an offer in compromise raised by                
          petitioner.                                                                 
                                     Discussion                                       
               Under section 6330, a taxpayer is entitled to notice and an            
          opportunity for a hearing before certain lien and levy actions              
          are taken by the Commissioner in the process of collecting unpaid           




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