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On September 5, 2003, petitioners asked Appeals for the
referenced hearing. On January 11, 2005, Linda Cochran
(Cochran), a settlement officer in Appeals, held the hearing with
petitioners’ counsel. Cochran and petitioners’ counsel discussed
two issues. The first issue concerned petitioners’ intent to
offer to compromise their 1981 through 1998 Federal income tax
liability due to doubt as to collectibility with special
circumstances and to promote effective tax administration.
Petitioners contended that Appeals should accept their offer as a
matter of equity and public policy. Petitioners stated that it
took a long time to resolve the Hoyt partnership cases and noted
that Hoyt had been convicted on the criminal charges. The second
issue concerned an interest abatement case under section 6404(e)
that petitioners had pending in this Court. That case related to
the same years at issue here. Petitioners claimed that the
proposed levy should be rejected because that case was pending.
On February 15, 2005, petitioners tendered to Cochran on
Form 656, Offer in Compromise, a written offer to pay $32,000 to
compromise their approximately $400,000 liability. Petitioners
supplemented their offer with a completed Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, four letters totaling approximately 65 pages, and
volumes of documents. The Form 433-A reported that petitioners
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Last modified: May 25, 2011