- 6 - 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 unpaidPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011