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On June 27, 2002, the Appeals officer held a telephone
hearing with petitioner. During the hearing, petitioner informed
the Appeals officer that he would submit an offer in compromise
based on doubt as to collectibility by August 1, 2002. On August
1, 2002, petitioner notified the Appeals officer that he would
need an additional 2 weeks to file the offer in compromise.
On August 27, 2002, the Appeals officer notified petitioner
by letter that he had an additional 2 weeks to submit an offer in
compromise.
On January 29, 2003, petitioner’s case was transferred to a
different Appeals officer. This Appeals officer determined that
there had been no action by petitioner with respect to his offer
in compromise.
On May 16, 2003, the Appeals officer notified petitioner
that he had until June 9, 2003, to submit his offer in
compromise. The Appeals officer provided petitioner with a Form
656, Offer in Compromise, and a Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals.
On June 11, 2003, petitioner submitted to the Appeals
officer a Form 656 based on doubt as to liability, and a Form
433-A. In the offer in compromise, petitioner stated that “This
tax was a result of a bank charging off a loan they made to a
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Last modified: May 25, 2011