Arthur Manjourides - Page 3

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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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