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counsel.5 Cochran and petitioners’ counsel discussed two issues.
The first issue concerned petitioners’ intent to offer to
compromise their 1982 through 1996 Federal income tax liability
to promote effective tax administration. Petitioners contended
that Appeals should accept their offer as a matter of economic
hardship, 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 June 7, 2005, petitioners tendered to Cochran on Form
656, Offer in Compromise, a written offer to pay $100,000 to
compromise their estimated approximately $275,000 liability. The
offer was limited to a claim of effective tax administration
because petitioners had sufficient assets to pay the liability in
full. Petitioners supplemented their offer with a completed Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, four letters totaling approximately 75
pages, and volumes of documents. The Form 433-A reported that
5 Petitioners were 69 and 72 years old at the time of the
hearing.
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