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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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Last modified: May 25, 2011