- 5 - Because the Brauns had individual retirement accounts totaling more than $46,000 but offered to pay approximately $2,500 of an $11,000 tax liability, including interest, respondent determined that petitioner’s offer was too low. Respondent rejected petitioner’s offer in compromise on collectibility and liability grounds. Respondent relied upon the shorter Form 433-F, that petitioner had originally submitted, in making his determination. Petitioner appealed. Appeal Offer in Compromise Determination The Appeals Office (Appeals) scheduled a conference with petitioner to discuss his offer in compromise. Petitioner canceled the meeting but increased his offer in compromise from $2,500 to $3,600. Appeals requested another conference with petitioner. Petitioner objected to the conference because he mistrusted respondent. Petitioner stated that he preferred all communication be in the form of written correspondence. Petitioner also charged respondent with making false statements, corresponding for the sole purpose of “finding funds” rather than to consider his offer, retaliating against him because he had exposed respondent’s “gestapo” tactics, and discriminating against him on account of sex, race, age, and marital status.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011