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as to collectibility.3 Petitioners offered to pay $10,000, with
$3,000 as an initial payment and 21 monthly payments of $333
thereafter. As of June 18, 2003, petitioners owed approximately
$33,006.31 in taxes, penalties, and interest for the years in
issue. Both the offer in compromise and the hearing request were
assigned to Settlement Officer Marilyn Q. Alls.
On July 7, 2003, a hearing was conducted by telephone
between Settlement Officer Alls and petitioner Donald A. Singer.
Settlement Officer Alls had no prior involvement with the taxes
that were the subject of the proceeding. In the hearing,
Settlement Officer Alls verified that all legal and procedural
requirements had been met. Amounts due had been properly
assessed, notice and demand had been made, the taxes were still
outstanding, and a levy source was identified and available.
Settlement Officer Alls verified that the proposed action
balanced the need for efficient collection of taxes with the
concern that any collection action be no more intrusive than
necessary.
In her review, Settlement Officer Alls determined that
petitioners had the ability to pay the liability in full over the
3Petitioners did not check any of the boxes in sec. 6 of
Form 656 to indicate the offer was based on doubt as to
collectibility or otherwise. However, the statement attached to
petitioners’ Form 656 claims they are unable to pay and mentions
no exceptional circumstances, such as permanent disability, that
would merit compromise based on effective tax administration.
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