- 4 -
plus interest.6 In addition, respondent made assessments of $800
for 1994 and $74.10 for 1997 against the Brauns in August 2003.
Offer in Compromise
Petitioner submitted his initial offer in compromise in the
form of a letter summarizing his job loss and physical injury.
In response, respondent withdrew penalties against the Brauns for
1994, except the estimated tax addition, and sent petitioner
proper forms for filing an offer in compromise. Respondent sent
to petitioner a Form 433-F, Collection Information Statement, and
Form 656, Offer In Compromise. Petitioner completed and returned
these forms to respondent, offering to compromise the Brauns’ tax
liability for $2,500. At that time, the Brauns’ tax liabilities
totaled approximately $11,000, including interest.
Respondent later requested a longer information statement
from petitioner, this time a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals.7
Petitioner refused to submit the longer Form 433-A, insisting
instead that respondent use the shorter Form 433-F, which he had
already submitted.
6The late-filed return for 1997 reflected a $4,317 tax
liability.
7Form 433-A, Collection Information Statement for Wage
Earners and Self-Employed Individuals, is six pages compared to
the one-page Form 433-F, Collection Information Statement,
respondent initially sent the Brauns.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011