- 30 - petitioner’s legitimate concern that the collection action be no more intrusive than necessary. The record does not support petitioner’s contention. Although petitioner completed an offer-in-compromise form, Mr. Burke did not submit the form to Settlement Officer O’Shea for consideration during their meeting on January 30, 2002, or at any time thereafter. Petitioner concedes that the parties informally suspended consideration of any offer-in-compromise pending a determination of Barbara Drake’s request for section 6015 relief. On September 4, 2002, subsequent to respondent’s denial of section 6015 relief to Barbara Drake, petitioner submitted an “amended” offer-in-compromise. In a letter dated September 4, 2002, Settlement Officer O’Shea informed Mr. Burke that no original offer-in-compromise had been submitted for consideration, and he returned the amended offer-in-compromise to Mr. Burke. Petitioner concedes that the reason for returning the amended offer-in-compromise was to avoid any administrative confusion. On April 10, 2003, Appeals Officer Kaplan informed Mr. Burke that no offer-in-compromise was presently before the Appeals Office. A letter from Appeals Officer Kaplan to Mr. Burke dated July 2, 2003, stated as follows: I have enclosed several collection information statements and the Offer in Compromise Questionnaire. If the taxpayers’ intent is to submit an Offer in Compromise as an alternative collection resolution to their case, please submit this document at this time. I have included the Offer in Compromise packet in thisPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011