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Respondent sought to reassure petitioner by letter that
Appeals was independent of other offices in the IRS. Respondent
explained that petitioner could openly discuss matters with
Appeals, that he had the right to legal representation at a
conference, and/or he could be accompanied by another person.
Again, petitioner refused respondent’s gesture and insisted upon
a written record of communication.
Petitioner raised his offer in compromise again, this time
to the full amount of the Brauns’ tax liabilities for 1994 and
1997, excluding interest.8 Petitioner’s amended offer also
required that respondent admit to having committed errors.
Investment Account Information
During consideration of petitioner’s offers, Appeals
requested the “current value” of petitioner’s 401(k) account.9
Twice petitioner sent respondent the current “vested” amount
rather than the “current value.” Respondent’s Taxpayer Advocate
(the TA) later explained the distinction to petitioner. The TA
also told petitioner that respondent should have requested “all”
8At that time, petitioner computed his full tax liability,
less interest, at $5,180.12. Petitioner later stated that his
full tax liability, less interest, was $4,586.27. Each time that
petitioner amended his offer in compromise, he did so by letter
to respondent, rather than by submitting an updated Form 656,
Offer in Compromise.
9On Mar. 25, 2002, petitioner replied that the current
vested balance in his 401(k) account was $1,671.59 as of Dec. 31,
2001. Later, petitioner reported that the current vested balance
in his 401(k) account was $4,384.54 as of Oct. 30, 2002.
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Last modified: May 25, 2011