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On August 18, 2003, Mr. Burke (but not petitioner) met with
Mr. O’Shea. Mr. Burke provided Mr. O’Shea with some, but not
all, of the information requested on the questionnaire. He did
not submit the offer form. Mr. O’Shea again extended the time
for completion of the questionnaire and submission of the offer
form, until September 2, 2003, and he informed Mr. Burke that no
further extension of time would be granted.
Petitioner did not submit the missing information or the
offer form to Mr. O’Shea by September 2, 2003, nor did petitioner
or Mr. Burke contact Mr. O’Shea between August 18 and September
2, 2003.
On September 10, 2003, Mr. O’Shea determined that collection
by levy of the unpaid tax should proceed. In part, Mr. O’Shea
based his determination on the fact that petitioner had failed to
submit information necessary for an offer in compromise. In
making his determination, Mr. O’Shea balanced the need for the
efficient collection of taxes with the concern that any
collection action be no more intrusive than necessary. He
verified that the requirements of applicable laws and
administrative procedures had been met.
Petitioner was notified of Mr. O’Shea’s determination by a
Notice Of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 dated October 2, 2003.
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