Michael Patrick and Lydia Brewer - Page 5

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                    We are requesting a hearing for the following                     
               reasons.                                                               
                    1) Knowing that I was going to be awarded a 100%                  
               disability by the VA, we attempted to effecutuate an                   
               OFFER IN COMPROMISE on three (3) separate occasions.                   
               The first one was requested in 1999.                                   
                    We were told by a variety of local CPA’s that the                 
               IRS was not staffed properly to administrate the OIC                   
               Program.  We informed the Taxpayer Advocate office in                  
               Phoenix of the forth coming Disability Rating and that                 
               we would appreciate an answer.  It took 3 years to get                 
               a response.                                                            
                    One Mrs. Holmes stated to me that we were “placed                 
               in UNCOLLECTIBLE STATUS” and that there “would be no                   
               liens”.  So it appears we were misguided.                              
                    Ms. Holmes also stated, quite succinctly, that                    
               “given the mountain of offers they are processing”,                    
               “your amount owed is not even worth setting up for                     
               payment plans”  That is a quote and it was recorded                    
               with acknowledgment.                                                   
                    I am now 100% Disabled Permanent and Total, as a                  
               result of fighting for the system that we all                          
               represent.  Since the rating I have developed                          
               additional medical problems, total knee replacement,                   
               and shingles.                                                          
                    My dear IRS officials, I made a due diligent                      
               attempt to pay you, and begged to process my offer                     
               sooner.  “Time is of the Essence” concept apparently                   
               has no play when it comes to the IRS.                                  
                    I believe I need professional assistance at this                  
               Hearing, so I have requested the accounting firm of                    
               Moran & Quick CPA’s to represent me.  The accountants                  
               name is Mark DeBenedetti CPA.                                          
               By letter dated February 2, 2004, an IRS Appeals officer               
          scheduled a conference with petitioners.  The letter also                   






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