Gregory Drake - Page 8

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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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