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(Wallace) wrote to Zerjav suggesting that Zerjav contact Wallace
to arrange a mutual date and time for the hearing to be conducted
with respect to petitioner’s liability. On October 16, 2001,
Wallace sent to Zerjav a letter requesting completion of an offer
in compromise package, including financial information. On
December 5, 2001, Wallace wrote to Zerjav scheduling a hearing
for January 15, 2002.
On January 14, 2002, Wallace received from Zerjav various
information concerning petitioner’s finances. In a telephone
conversation on January 14, 2002, Zerjav advised Wallace that
petitioner wanted to pursue an offer in compromise. No
person-to-person hearing took place on January 15, 2002.
Appeals Officer Wallace reviewed the financial information
submitted by petitioner. He considered petitioner’s income and
the income of petitioner’s mother, because petitioner’s mother
lived with petitioner and was supported in part by petitioner.
Wallace concluded that, after allowable expenses, petitioner
could pay $82 per month toward his tax liability. In a letter
dated February 28, 2002, Wallace proposed three alternatives:
(1) A cash offer of $3,936 (computed as 48 months multiplied by
$82 per month); (2) a short-term deferred payment offer of
$4,920, payable over 2 years (60 months multiplied by $82 per
month); and (3) a deferred payment offer of $6,888 (84 months
multiplied by $82 per month). Wallace’s proposals were based on
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Last modified: May 25, 2011