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1996, and 1999. The request stated that petitioner disagreed
with the amounts of the assessed deficiencies and that he wished
to submit an offer-in-compromise because he was unable to satisfy
the tax liability due to his health and financial conditions.
On May 20, 2003, respondent sent petitioner an offer-in-
compromise package to fill out and bring to his section 6330
hearing.
By letter dated January 15, 2004, Appeals Officer Zane
Janish (Mr. Janish) contacted petitioner regarding his section
6330 hearing request. Mr. Janish stated that petitioner needed
to complete and submit the enclosed Form 433-A, Collection
Information Statement For Individuals, and his delinquent 2001
and 2002 Federal income tax returns by February 17, 2004, in
order for petitioner’s offer-in-compromise to be considered. Mr.
Janish also warned petitioner that if petitioner did not submit
the requested documents by February 17, 2004, petitioner’s
section 6330 hearing “will consist of a review of the information
in [petitioner’s] * * * request and case file.” Petitioner
failed to submit the Form 433-A and his 2001 and 2002 tax
returns6 to Mr. Janish.
6Petitioner did not file his 2001 and 2002 tax returns until
Mar. 17, 2004.
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Last modified: May 25, 2011