- 10 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011