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subsequently advised Mr. Burke that no offer-in-compromise was
presently before the Appeals Office, as no original offer-in-
compromise had been submitted for consideration and the amended
offer-in-compromise had been returned to Mr. Burke. Appeals
Officer Kaplan informed Mr. Burke that any offer-in-compromise
should be larger than the $5,500 amended offer-in-compromise
submitted on September 4, 2002. Appeals Officer Kaplan also
noted that the former residence of Barbara Drake and petitioner
was now owned by their son and that the transfer appeared
questionable.
In a conversation on June 16, 2003, Mr. Burke informed
Appeals Officer Kaplan that Darren Drake, the son of Barbara
Drake and petitioner, had foreclosed upon and bought petitioner’s
house. Appeals Officer Kaplan requested documentation related to
the foreclosure and transfer.
In a letter dated July 2, 2003, Appeals Officer Kaplan made
the following request, reproduced verbatim, for the production of
documents:
1. Documentation regarding what was done with the
funds received by the taxpayers from the sale of
property as part of their bankruptcy proceedings,
along with how much was actually received.
2. Documentation of the value of the property located
at 40 Keel Cape Drive, South Yarmouth, MA, prior
to the foreclosure.
3. Documentation of the foreclosure.
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