Joseph G. Dostal - Page 10

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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, 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                            

                  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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