- 7 - their fourth offer in compromise by facsimile letter, only to inform them several months later that such offer was not in proper form and therefore could not be considered, (5) took 6 months to deliver copies of requested transcripts of account, (6) failed to provide petitioners a copy of their “master file”, as requested in their fourth offer in compromise, (7) did not accept petitioners’ proposal for an installment agreement, which called for a monthly payment based on petitioners’ excess monthly income, as previously determined by IRS personnel, (8) failed to respond to petitioners’ 1997 letter requesting abatement of additions to tax, (9) failed to grant petitioners a requested Appeals conference following the rejection of their fifth offer in compromise, and (10) ignored petitioners’ requests for copies of their transcripts of account and an Appeals conference following the rejection of their 1998 request for abatement of interest and additions to tax. III. Analysis A. Allegations 8-10 We begin with petitioners’ allegations numbered 8, 9, and 10 above. Petitioners did not raise any of those allegations in their request for interest abatement; indeed, allegations 9 and 10 involve acts and omissions that could not have predated petitioners’ filing of that request. Furthermore, the record is devoid of any evidence that petitioners subsequently advisedPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011