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compromise the outstanding liabilities and penalties.3
Petitioner paid $1,000 with the submission of the offer and the
remaining $99,000 with borrowed funds within 60 days after
acceptance of the offer.
Petitioner agreed to the following terms and conditions:
(d) I * * * will comply with all the provisions
of the Internal Revenue Code related to
filing my * * * returns * * * for five (5)
years from the date IRS accepts the offer.
* * * * * * *
(j) I * * * understand that I * * * remain
responsible for the full amount of the tax
liability unless and until IRS accepts the
offer in writing and I * * * have met all the
terms and conditions of the offer. IRS won’t
remove the original amount of the tax
liability from its records until I * * * have
met all the terms and conditions of the
offer.
* * * * * * *
(o) If I * * * fail to meet any of the terms and
conditions of the offer, the offer is in
default, and IRS may:
* * * * * * *
(iv) file suit or levy to collect
the original amount of tax
3 As additional consideration, petitioner signed a Form
2261, Collateral Agreement, in which he also agreed to pay 40
percent of his annual income in excess of $100,000 and not in
excess of $130,000; 50 percent of annual income in excess of
$130,000 and not in excess of $150,000; and 60 percent of annual
income in excess of $150,000. Petitioner’s annual income was
less than $100,000 for 1995, 1996, 1997, 1998, and 1999.
Accordingly, petitioner was not required to pay additional
consideration.
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