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On January 29, 2002, Mr. Blais conducted a section 6330
hearing (hearing) with petitioner’s representatives--Ms. Lotter
and Scott O’Connell. Mr. Blais never spoke to petitioner. At
the hearing, Mr. Blais considered the 1989 return. On its face,
the 1989 return appeared unusual to Mr. Blais. Mr. Blais advised
petitioner’s representatives that he could not adjust or abate a
tax without evidence as to the amount of petitioner’s true income
for 1989. Petitioner’s representatives advised Mr. Blais that
petitioner had no books or records for 1989 and also disagreed
with the nominee liens.
The focus of the hearing, however, was whether petitioner’s
case could be settled through an OIC; i.e., petitioner proposed
an OIC as a collection alternative. Petitioner suggested a
compromise consisting of a percentage of the equity of the
properties held in the three trusts. Mr. O’Connell stated that
he could provide Mr. Blais with information that would help Mr.
Blais determine a settlement figure (via an OIC). Petitioner was
willing and prepared to present any documents Mr. Blais needed.
On January 29, 2002, Mr. Blais made the following entry into
his case activity record: “best case scenario on nominee leaves
about 77K collectible * * * Ms. Lotter to determine if t/p can
raise add’l funds for OIC in projected settlement range with
hazards figured in”.
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Last modified: May 25, 2011