Gregory Drake - Page 17

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          representative.9  At the conclusion of the aforementioned                   
          conference, respondent’s Associate Area Counsel John V. Cardone             
          (Attorney Cardone) met with Mr. Burke and Appeals Officer Kramer            
          to discuss the possibility of an offer-in-compromise.10  On                 
          behalf of petitioner, Mr. Burke submitted another collection                
          information statement, and he agreed to submit a new offer-in-              
          compromise by November 14, 2005.  Petitioner was asked to submit            
          certain documents by November 14, 2005, to verify petitioner’s              
          collection information statement.  Attorney Cardone informed Mr.            
          Burke that any offer-in-compromise should include the 1997                  
          bankruptcy sale proceeds.                                                   
               Mr. Burke subsequently submitted on petitioner’s behalf an             
          offer-in-compromise in the amount of $75,000, representing                  
          approximately one-half of the 1997 bankruptcy sale proceeds.  The           
          offer-in-compromise was based on doubt as to collectibility and             
          the promotion of effective tax administration.  On January 19,              
          2006, respondent accepted the offer-in-compromise for processing.           

               9On Mar. 31, 2006, we ordered petitioner to file a response,           
          setting forth clear and concise assignment of each and every                
          error which petitioner alleges to have been committed with                  
          respect to the supplemental notice of determination.  Petitioner            
          made no contention that Appeals Office Kramer either had a prior            
          involvement with petitioner or had received a communication                 
          relating to the credibility of petitioner or petitioner’s                   
          representative.  Consequently, those issues are deemed to be                
          conceded by petitioner.  See Rule 331(b)(4).                                
               10Pursuant to sec. 7122(b), any offer-in-compromise                    
          exceeding $50,000 requires the opinion of the General Counsel for           
          the Department of the Treasury or his delegate.                             





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