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In due course after submission of petitioner’s offer-
in-compromise, the Appeals officer wrote to petitioner
stating that she had been assigned petitioner’s hearing.
In her letter, the Appeals officer noted that petitioner
had submitted an offer-in-compromise, and she said that the
offer would be “considered as a part of your collection due
process hearing”. In that connection, the Appeals officer
stated as follows:
I have reviewed your offer and the financial
documentation submitted by your representative.
It does not appear based on upon [sic] the
provisions, conditions and examples provided
in the Internal Revenue Regulations section
301.7122-1(c)(3) and in the Internal Revenue
Manual section 5.8.22.2(4), that you qualify
for an Effective Tax Administration Offer in
Compromise due to economic hardship. I will be
happy to discuss other alternative collection
options with you, such as an installment
agreement.
Petitioner’s attorney met with the Appeals officer
in her office on April 20, 2004. Following that meeting,
petitioner’s attorney sent the Appeals officer a letter
dated May 5, 2004, transmitting various documents which
the Appeals officer had requested. Among the documents
were statements from two brokerage firms, National
Securities Corp. and Piper Jaffray, which show that as
of March 31, 2004, petitioner and his wife had brokerage
accounts valued at $179,836.67, as follows:
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Last modified: May 25, 2011