Gregory Drake - Page 10

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               4.   Documentation regarding the amount owed on the                    
                    mortgage by the taxpayers at the time of the                      
                    foreclosure.                                                      
               5.   Documentation regarding the entity that acquired                  
                    the mortgage from the prior mortgage holder prior                 
                    to the foreclosure.                                               
               6. Copies of the mortgage.                                             
               7.   Documentation of the acquisition of the property                  
                    by Darren Drake.                                                  
               8.   An updated Collection Information Statement for                   
                    Mr. and Mrs. Drake.                                               
               9.   Completed Offer-in-Compromise Questionnaire.                      
               10. An updated Collection Information Statement for                    
                    their businesses.                                                 
          Appeals Officer Kaplan informed Mr. Burke that he would make a              
          determination pursuant to section 6330 (section 6330                        
          determination) based on information already within his possession           
          unless Mr. Burke submitted the requested documents by July 30,              
          2003.  In addition, Appeals Officer Kaplan informed Mr. Burke               
          that any offer-in-compromise should also be submitted.  In August           
          of 2003, Mr. Burke provided respondent’s Appeals Office with a              
          portion of the requested documents but did not submit                       
          documentation related to the 1997 bankruptcy sale proceeds.  On             
          August 26, 2003, Appeals Officer Kaplan informed Mr. Burke that             
          he had not received all of the requested information.  Again, on            
          September 16, 2003, Appeals Officer Kaplan verbally reminded Mr.            
          Burke that all of the requested information had not been received           
          by respondent.                                                              





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