- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011