Michael Patrick and Lydia Brewer - Page 4

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          military service in Vietnam.  The Department of Veterans Affairs            
          has concluded that he is 100-percent service disabled.                      
               In November 1999, petitioners submitted an offer in                    
          compromise (OIC) to respondent.  According to petitioner, the OIC           
          forms were revised by respondent and petitioners submitted a new            
          or revised OIC in May 2000.  By letter dated October 5, 2000, the           
          IRS advised petitioners that the OIC was still awaiting                     
          assignment to an appropriate IRS representative.  The offer was             
          apparently rejected by respondent on January 31, 2002.  The                 
          record does not contain copies of the OIC or a rejection of the             
          OIC.  Respondent’s case activity record indicates that the OIC              
          was rejected for failure to submit required financial                       
          information.                                                                
               On April 10, 2003, respondent filed a notice of Federal tax            
          lien with respect to the tax liabilities for the taxable years              
          1992, 1994, 1996, and 2000; and on April 15, 2003, respondent               
          issued to petitioners a Notice of Federal Tax Lien Filing and               
          Your Right to a Hearing Under IRC 6320.  The notice reflects a              
          balance owed of $9,027.02 for said years.  Petitioners timely               
          requested a hearing on Form 12153, Request for a Collection Due             
          Process Hearing, with the IRS Office of Appeals.  Petitioners               
          explained in the request:                                                   
                    There are two reasons.  One is that I knew I would                
               soon be 100% disabled and never able to pay.  Second,                  
               Mrs. Holmes in Phoenix told us we went to the                          
               “uncollectable status”.                                                





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