Mitchell F. Skrizowski - Page 9

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               On March 29, 2002, Mr. O’Connell provided documents to Mr.             
          Blais.  Mr. Blais concluded that an OIC was possible, but                   
          additional investigation was necessary and needed to be done at a           
          “lower level”.  Mr. Blais did not feel comfortable determining a            
          settlement figure.  That same day, Mr. Blais wrote petitioner’s             
          attorneys:                                                                  
               I can state with reasonable certainty that sufficient                  
               resources do not appear to exist to liquidate the full                 
               amount of the delinquent tax liability.  Although, an                  
               Offer in Compromise appears to be a likely method of                   
               resolving the dispute; the information submitted so far                
               is not adequate to quantify an amount or a range of                    
               amounts that appear acceptable.  In order to fully                     
               exhaust this method of resolution I propose to return                  
               the Offer in Compromise portion of my case to the                      
               Compliance function so they can fully develop and                      
               quantify an equity/asset position.  If an agreement                    
               cannot be reached at that level the Offer may receive                  
               additional consideration from Appeals.                                 
          The letter concluded:  “The complex nature and numerous                     
          transactions regarding the Offer in Compromise warrant additional           
          investigative work by the Compliance function prior to a                    
          resolution acceptable by both parties.”  Mr. Blais sent the OIC             
          to the “OIC group” for additional investigation.                            
               On April 10, 2002, Mr. Blais prepared an Appeals case                  
          memorandum.  In the Appeals case memorandum, Mr. Blais wrote:               
          “There is no evidence that the taxpayer had 5 million dollars to            
          purchase trust property and finance the business dealings” and              
          that bankruptcy proceedings “did not uncover any assets or cash             
          that might have been available to start the type of entities now            






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