Robert Conde Del'Giudice - Page 4

                                        - 3 -                                         
          filing (NFTLF) with respect to 1999 and 2001 on April 28, 2004.             
          As petitioner’s request for a hearing was not timely filed as to            
          the NFTLF for 1999 and 2001, he received only an equivalent                 
          hearing on those issues.  Petitioner has accumulated tax                    
          liabilities of more than $24,000 for 1999, 2000, 2001 and 2003.             
          The record does not reflect any activity by respondent relative             
          to 2003.                                                                    
               On the same date that petitioner filed his Form 12153,                 
          respondent received from petitioner a letter stating that he had            
          submitted a Form 656, Offer-in-Compromise (OIC), on account of              
          doubt as to collectibility, for 1999, 2000, and 2001.  The OIC,             
          received on January 12, 2004, was returned.  Petitioner                     
          resubmitted his OIC along with a Form 433-A, Collection                     
          Information Statement for Wage Earners and Self-Employed                    
          Individuals, both dated May 29, 2004.  Petitioner later                     
          supplemented his OIC with additional information attached to an             
          “Amended/Revised” OIC signed and dated July 6, 2004.  The                   
          amended/revised OIC included 2003 as well as 1999, 2000, and                
          2001.  In November of 2004, petitioner sent to respondent a                 
          letter enclosing an “updated” Form 433-A with attachments.                  
               All of petitioner’s OICs requested a “Short-Term Deferred              
          Payment Offer”, which must be paid more than 90 days, but within            
          24 months, from acceptance.  Petitioner offered to pay $2,500 on            
          his outstanding tax liabilities in all three versions of his OIC.           

Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011