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2000, a letter that Chambers had prepared for petitioners to
sign. The letter stated (without explanation) that petitioners
requested to withdraw their pending offer in compromise for 1991-
95. Petitioner signed the letter and returned it to Chambers on
July 27, 2000. Davis told petitioners that their offer in
compromise to settle their liability for 1991-95 was considered
withdrawn on July 28, 2000.
2. Administrative Proceedings Under Section 6330(b)
Respondent filed a notice of Federal tax lien with respect
to petitioners’ 1991-95 Federal income tax liabilities 2 days
after petitioners withdrew their offer in compromise. The lien
adversely affected petitioner’s credit, including his ability to
buy alarm equipment on credit to install for his customers.
On August 2, 2000, petitioners timely filed a request for a
collection due process hearing.
On dates not stated in the record: (a) Petitioner asked
respondent’s employees (not identified in the record) why
respondent had filed a Federal tax lien; (b) petitioner was told
that he had not resubmitted an offer in compromise; (c)
petitioners submitted to respondent a offer in compromise that
Holder had helped to prepare; (4) respondent did not accept it
because petitioners had not filed all tax returns that were due;
and (5) petitioners prepared returns that were due and submitted
them with the offer in compromise.
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