- 13 -
During our conference, we advised that you did
not qualify for an ETA offer [an offer in
compromise based upon Effective Tax Administra-
tion] because you had not demonstrated that you
had an undue hardship as defined under the Code
of Federal Regulations Section 6343-1. We
advised that you had the ability to full pay
your tax liability and we proposed that your
representative ask you to consider an installment
agreement and/or liquidation of your retirement
accounts in order to satisfy the tax liability.
We asked your representative to provide us with
some additional documentation which included a
draft of your Form 1040 for 2003. We advised
that you could not owe a balance due if you still
wished to pursue an offer.
On May 10, 2004 we received some additional
documentation from your representative. In his
cover letter, your representative advised us that
you were going to owe $70,000.00 for the tax year
2003 and intended to pay the amount due with
funds from your retirement accounts.
On May 19, 2004 and May 25, 2004, we held
telephone conferences with your representative
and advised that we could no longer consider an
offer because you had not complied with your
payment requirements and had incurred another
liability while your offer was being considered.
We noted that the current balance in your
retirement accounts was approximately
$178,000.00. Your representative asked if you
could enter into an installment agreement. We
advised that we would consider an installment
agreement if you paid your 2003 tax year in full,
made a substantial payment towards your tax
liability for 2000 and 2001, and provided some
missing documentation in order to determine the
precise amount of your monthly installment
payment. * * *
Your representative advised that he would
discuss the proposal with you. We asked to be
contacted by June 1, 2001 [sic]. On May 26, 2004
we sent and faxed a letter to your representative
outlining the terms under which we could consider
an installment agreement. On June 1, 2004, your
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011