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to Mr. Whitinger that petitioners file an offer-in-compromise
with respect to their 1999 tax liability.4
On January 30, 2004, Ms. Cahill sent petitioners the
necessary offer-in-compromise forms, including Form 656,
Application for Offer in Compromise, and Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, to be completed and returned to respondent.
Subsequently, Ms. Cahill received from petitioners a completed
Form 656. However, petitioners did not include Form 433-A or the
appropriate filing fee. Ms. Cahill informed petitioners that
both Form 433-A and the filing fee must be submitted before
respondent could process their offer-in-compromise. At no time
did petitioners submit to respondent Form 433-A or the filing
fee.
Ms. Cahill reviewed respondent’s administrative record but
could not verify petitioners’ claim that they were informed by
Mr. Sherrill that their $363 payment made with respect to the
1999 deficiency was a full settlement of their 1999 tax
liability. Ms. Cahill again spoke with Mr. Whitinger to inform
petitioners as to their available options and to advise them that
the amount of tax due as reported on petitioners’ 1999 return
remained unpaid.
4 Petitioners had previously submitted an offer-in-
compromise prior to receiving the notice of deficiency. This
offer-in-compromise was rejected by respondent on Mar. 7, 2001.
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Last modified: May 25, 2011