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of Barbara Drake’s request for section 6015 relief, which would
influence whether petitioner filed an individual offer-in-
compromise or a joint offer-in-compromise.
On September 4, 2002, petitioner submitted to respondent’s
Appeals Office an “amended” offer-in-compromise form. The
amended offer-in-compromise listed petitioner alone as the
taxpayer and offered to pay $5,500 in satisfaction of
petitioner’s tax liabilities for 1991, 1992, 1993, 1994, 1995,
1997, and 1999. In a letter to Mr. Burke dated September 4,
2002, Settlement Officer O’Shea acknowledged receiving the
amended offer-in-compromise but noted that consideration of the
original offer-in-compromise had been informally suspended by the
parties pending the determination of Barbara Drake’s request for
section 6015 relief. Accordingly, Settlement Officer O’Shea
informed Mr. Burke that no original offer-in-compromise had been
submitted for consideration and returned the amended offer-in-
compromise to Mr. Burke. Petitioner concedes that the reason for
returning the amended offer-in-compromise form was to avoid any
administrative confusion.
B. Proceedings Before Appeals Officer Kaplan
On January 17, 2003, the section 6330 matter was transferred
from Settlement Officer O’Shea to Appeals Officer Jeffrey Kaplan,
who had been assigned to the administrative appeal of Barbara
Drake’s request for section 6015 relief. Appeals Officer Kaplan
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