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“I filed an Offer in Compromise for the tax liabilities in
question on March 15, 2002.”
By a letter dated August 30, 2002, Settlement Officer
Ronald J. Kroll (Mr. Kroll) advised petitioner that he had
received petitioner’s case for Appeals consideration and would
write or call to schedule a conference. Mr. Karaszkiewicz
responded by a letter dated September 24, 2002, requesting that
Mr. Kroll contact him to arrange a mutually convenient
conference.
Mr. Kroll investigated concerning the reference to an offer
in compromise made in petitioner’s Form 12153. He found that
while an earlier offer in compromise, apparently submitted in
about December of 2000, had been returned to petitioner in
December of 2001, Internal Revenue Service records did not
reflect a March 15, 2002, offer. When Mr. Kroll advised
Mr. Karaszkiewicz by telephone on October 2, 2002, of what he had
learned, Mr. Karaszkiewicz said that the earlier offer had been
returned because additional documentation requested had not been
timely submitted. Mr. Karaszkiewicz also indicated that he would
send a copy of the subsequent March 15, 2002, Form 656, Offer in
Compromise, and Form 433-A, Collection Information Statement for
Wage Earners and Self-Employed Individuals.
On November 22, 2002, having not received the promised
copies of Forms 656 and 433-A, Mr. Kroll sent to
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