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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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