- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011