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the January 11, 2006 Memorandum Decision and January 12, 2006
Order of the Bankruptcy Court.”
In a letter to Appeals Officer Kramer dated January 28,
2006, Mr. Burke stated, inter alia, (1) that he believed that the
section 6330 hearing on remand included Barbara Drake as a
consequence of the bankruptcy court’s decision in In re Drake,
336 Bankr. at 156; (2) that all parties to the matter agreed to
the settlement terms; and (3) that the “taxpayers” were amending
their offer-in-compromise to reflect the settlement terms, with
the exception of the proposed waiver of petitioner’s claim for
litigation costs and fees.
On April 13, 2006, petitioner filed a “Motion to Compel
Settlement”, contending that Mr. Burke accepted a settlement
offer from respondent on January 6, 2006, and requesting that the
Court enforce such settlement.
D. The Supplemental Notice of Determination
On March 13, 2006, respondent’s Appeals Office issued to
petitioner a notice of determination (the supplemental notice of
determination), setting forth the following determination:
The proposed collection action is sustained. You did
not provide sufficient information for the evaluation
of your proposed collection alternative. Consequently,
your Offer could not be evaluated and is being
rejected. The jeopardy levy is sustained. The
attachment to this Determination Letter contains
additional details.
In the aforementioned attachment to the supplemental notice of
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