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It is in the best interest of the government and
the taxpayer that an Offer in Compromise be entered into.
Accordingly, the taxpayer requests that the
government enter into a voluntary agreement to address
the taxpayer’s past due taxes.
The Appeals officer advised petitioner’s counsel, Timothy
Burke (Mr. Burke), that petitioner had not filed Federal income
tax returns for taxable years 1997 through 2002 and that he would
need to file them by November 17, 2003, before any collection
alternative could be considered. On October 27, 2003, petitioner
filed his Federal income tax returns for 1997 through 2002,
reporting a balance due for each year.
On August 6, 2004, Mr. Burke contacted the Appeals officer
to discuss the possibility of petitioner’s entering into an
installment agreement.2 On August 16, 2004, petitioner submitted
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, and Form 433-B, Collection Information
Statement for Businesses. On Form 433-A, petitioner indicated,
among other things, that he owned a “50% Interest” in certain
real property in Boston, Massachusetts (the real estate).
Petitioner listed the current value of his interest in the real
2 The Appeals officer’s case activity report indicates that
Mr. Burke had acknowledged that petitioner was ineligible for an
offer-in-compromise.
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Last modified: May 25, 2011