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and 2000, reflecting a balance due of $7,729.33. Petitioner
replied by returning to respondent a Form 12153, Request for a
Collection Due Process Hearing.
1. Petitioner's Hearing
In his request for a hearing, petitioner alleged that he had
attempted unsuccessfully to enter into a payment agreement to
satisfy his outstanding liability. The Appeals Office sent him
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, to ascertain the feasibility of
collection alternatives. Petitioner submitted some financial
information, and Settlement Officer Jean Frazier (Ms. Frazier)
held a telephone conference with petitioner.
During the conference, petitioner informed Ms. Frazier that
he wanted to submit an offer in compromise. Ms. Frazier provided
petitioner with Form 656, Offer in Compromise (OIC), and
requested some additional information and documentation as well
as an estimated tax payment. Petitioner provided the information
and documentation requested but failed to sign the OIC and did
not submit an estimated tax payment. Ms. Frazier nevertheless
reviewed the information petitioner provided and concluded that
he had the ability to pay his tax liability in full.
At this point, petitioner began to dispute the underlying
tax liability. Ms. Frazier explained to petitioner that the tax
liability was based on returns petitioner had filed. She gave
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Last modified: May 25, 2011