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interest. Watson told petitioners that they needed to file
returns for 2000 and 2001 that had not been filed. Watson sent
offer in compromise forms to petitioners, closed the case on
January 24, 2002, and so informed petitioners.
Petitioners submitted an offer in compromise on May 24,
2002. In it, petitioners did not check the box to indicate
whether the offer was on account of doubt as to liability or as
to collectibility and did not state an amount to settle their
case. Respondent returned the offer in compromise because
petitioners had not filed their 2000 or 2001 return.
Petitioners submitted another offer in compromise on June 3,
2002, in which they offered to pay $850 to satisfy their
liabilities for the years in issue. They also submitted a Form
433-B for their business in which they separated petitioner’s
personal income and gross business receipts. Petitioners did not
check the box on the form to indicate whether the offer was on
account of doubt as to liability or as to collectibility.
3. The Taxpayer Advocate Service
On June 10, 2002, petitioners wrote to respondent’s Taxpayer
Advocate Service office in Jacksonville, Florida, and asked it to
expedite the processing of their offer in compromise and to
release the lien. Petitioners wanted their offer in compromise
to be considered by an office near their home. On June 13, 2002,
Diane Wilkes (Wilkes), an employee in respondent’s Taxpayer
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Last modified: May 25, 2011