- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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