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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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Last modified: May 25, 2011