Mitchell F. Skrizowski - Page 8

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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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