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Mr. Karaszkiewicz a letter referencing the copies and stating, in
pertinent part:
I have not received these documents. The offer was the
only collection alternative proposed in your appeal.
Please be advised that I am offering one final
opportunity for you to provide the information for
consideration as an alternative means of collection.
You have 15 days from the date of this letter to file
an offer in compromise or send me a written proposal on
how you plan to resolve these liabilities. Enclosed
are Forms 656 and 433-A.
If the documents are not received within 15 days, I
will issue a determination letter based on current
information. No further extensions or exceptions will
be considered.
On November 26, 2002, Mr. Karaszkiewicz sent to Mr. Kroll copies
of the requested documents.
The offer in compromise proposed to pay a total of $15,000
by remitting $5,000 within 90 days of acceptance and the balance
in 10 monthly installments of $1,000. In conjunction with his
review of the offer, Mr. Kroll both contacted Mr. Karaszkiewicz
by telephone with questions regarding the materials provided and
subsequently sent a letter dated January 21, 2003,2 requesting
additional information necessary for consideration of the offer.
The letter also advised: “Please see that I receive the
requested information no later than February 18, 2003. Failure
to submit the information may result in the recommendation that
2 We note that Mr. Kroll’s case activity record in one
instance, specifically the entry for March 10, 2003, apparently
refers to this letter erroneously as the “1/31/03 letter”.
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