Michael W. Braun - Page 5

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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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