- 8 - 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 KaplanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011