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E. Whether Appeals Officer Kramer Improperly Rejected
Petitioner’s Offer-in-Compromise.
We understand petitioner to contend that Appeals Officer
Kramer improperly rejected petitioner’s offer-in-compromise.25
Petitioner contends that Appeals Officer Kramer erred in
determining that petitioner did not submit requested financial
verification documents because Appeals Officer Kramer neither
requested documentation nor set forth a deadline for petitioner
to submit such documentation after accepting petitioner’s offer-
in-compromise for processing on January 19, 2006. Petitioner
further contends that the global settlement agreement “mooted”
any request for documentation made prior to January 6, 2006.
If an offer-in-compromise that has been accepted by the IRS
for processing does not contain sufficient information to permit
the IRS to evaluate whether the offer should be accepted, the IRS
will request that the taxpayer provide the needed additional
information.26 Sec. 301.7122-1(d)(2), Proced. & Admin. Regs. In
25With respect to petitioner’s offer-in-compromise,
petitioner’s primary contention is that “Respondent erred in
failing to compromise the parties’ dispute on the terms of the
[global settlement] Agreement.” Because we previously addressed
petitioner’s contention that the parties entered into a
settlement agreement, we now address petitioner’s related
contention that petitioner did not receive a request for further
information from respondent.
26If the taxpayer does not submit the additional information
that the IRS has requested within a reasonable time period after
such a request, sec. 301.7122-1(d)(2), Proced. & Admin. Regs.,
(continued...)
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