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Offer in Compromise. By the Form 656, petitioner proposed to
compromise his unpaid income tax liabilities from 1990 through
2001 (later limited to 1992 through 2001 since the period of
limitations on collection for 1990 and 1991 had run).
Petitioner’s unpaid income tax liabilities for 1992 through 2001
(the 1992-2001 liability) total $275,777. Petitioner offered to
pay $10,000 in compromise of the 1992-2001 liability (sometimes,
the offer or the offer in compromise), such amount to be paid
within 24 months of acceptance of the offer. Petitioner checked
boxes on the Form 656 justifying the offer by reason of both
“Doubt as to Collectibility” (i.e., he had insufficient assets
and income to pay the full liability) and “Effective Tax
Administration” (i.e., he had sufficient assets to pay the full
liability but, due to his exceptional circumstances, requiring
full payment would cause an economic hardship or would be unfair
and inequitable). In the portion of the form requesting an
explanation of circumstances affecting the taxpayer’s ability to
fully pay the amount due, petitioner stated: “Please see
attached.” No attachment accompanies the copy of the form
stipulated by the parties.
During the October 3 meeting, Ms. Boudreau asked Mr. Burke
about the exceptional circumstances claimed by petitioner. Mr.
Burke responded that petitioner was ill, but he would not
disclose the nature of the illness, citing petitioner’s wish on
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