Russel S. Bankson - Page 4

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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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