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compromise his tax liabilities for the taxable years 2000 and
2001.1 The OIC was based on doubt as to collectibility.
Included with the OIC was a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals. The
Form 433-A states that petitioner is unemployed, earns no income,
and has monthly expenses of $745. Also included with the OIC was
a letter from Heidi Bernd (Ms. Bernd). The letter is dated June
6, 2003, and states: “I hereby confirm that Russel S. Bankson * *
* has resided in my household since 9/01/01 and does not pay
contractual rent. He does, however, contribute to household
expenses as his available income allows.”
Petitioner’s OIC was assigned to an Appeals officer, who
held an administrative hearing with petitioner by correspondence.
In April 2004, the Appeals officer sent petitioner a letter
requesting, inter alia, information about his employment history
and expenses, as well as “verification of income” for Ms. Bernd.
Petitioner’s reply letter reiterates that he is unemployed. It
also explains that petitioner performs various personal services
for Ms. Bernd, such as chauffeuring and shopping, in exchange for
living with her. The letter includes copies of petitioner’s
credit card statements for certain months in 2003, but does not
include verification of Ms. Bernd’s income.
1 Petitioner’s OIC also included the taxable years 1999 and
2002. Those taxable years are not before the Court.
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Last modified: May 25, 2011