Mitchell F. Skrizowski - Page 5

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          Petitioner’s Activities During the Mid-1990s                                
               In the mid-1990s, petitioner obtained employment renovating            
          buildings.  Old friends unable to sell their properties offered             
          those properties to petitioner.  The properties were placed into            
          one of three trusts (three trusts):  Pangia Trust, Joshua                   
          Irrevocable Trust, or Good Apple Trust.  The trustees were a                
          friend of petitioner’s family and/or one of petitioner’s                    
          children.  The beneficiaries were petitioner’s three children.              
          Petitioner’s Disability and Deteriorating Health                            
               Petitioner has been ruled permanently and totally disabled.            
          He collects approximately $1,400 per month of disability income             
          from Social Security.                                                       
               In 1999, petitioner was diagnosed with hepatitis C.  He has            
          been hospitalized for jaundice, and he has cirrhosis of the                 
          liver.  Petitioner’s prognosis was that he had approximately a 75           
          percent chance of developing cancer within 5 years.  Petitioner             
          wanted to resolve his problems with the IRS while he was still              
          somewhat healthy.                                                           
          Petitioner’s Submission of an Offer-In-Compromise                           
               On or about March 16, 2000, petitioner submitted an offer-             
          in-compromise (OIC) seeking to compromise his 1986, 1987, 1988,             
          1989, and 1992 Federal income tax liabilities for $5,000.                   
          Petitioner submitted the OIC on the grounds of doubt as to                  
          collectability.  Offer Specialist John Mahalaris was assigned to            
          investigate the OIC.                                                        




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