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Earners And Self-Employed Individuals, seeking to compromise his
liabilities for tax years 1997 through 2002 on the grounds of
doubt as to collectibility and effective tax administration.
Petitioner’s OIC was assigned to Revenue Officer Glen McDuffie
(Mr. McDuffie) for consideration.
Mr. McDuffie was contacted by Settlement Officer Patrick Lin
(Mr. Lin) who informed him that petitioner had filed a Form 12153
and that Mr. Lin was retaining jurisdiction over the case. Mr.
Lin asked Mr. McDuffie to complete his investigation of
petitioner’s OIC but informed him that Mr. Lin would make the
final determination whether to accept or reject the OIC.
Mr. McDuffie sent petitioner a preliminary analysis of his
OIC in which Mr. McDuffie determined that petitioner had the
ability to pay a total of $148,961 based on the equity in
petitioner’s home and that petitioner could pay his tax
liabilities in full. Petitioner offered $1,000 to satisfy his
outstanding liabilities of $91,267.08. Mr. McDuffie forwarded
petitioner’s case to Mr. Lin for review and reconsideration.
C. Petitioner’s Hearing
At his conference with Mr. Lin, petitioner agreed to list
his residence for sale and remit the sales proceeds by certain
deadlines and to enter into an installment agreement for the
remaining balance. Mr. Lin sent petitioner a confirmation letter
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Last modified: May 25, 2011