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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.
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Last modified: May 25, 2011