- 42 - the instant case, during the conference between Mr. Burke and Appeals Officer Kramer on November 4, 2005, Mr. Burke was asked to submit additional documents needed for the evaluation of petitioner’s offer-in-compromise by November 14, 2005. Petitioner neither disputes that such a request was made nor contends that such documents were in fact submitted in response to the request. Based on the administrative record in the instant case, we are unable to conclude that the global settlement negotiations affected the document request as alleged by petitioner. More than 4 months elapsed from the date of the document request until the issuance of the supplemental notice of determination, and Appeals Officer Kramer was not required to make further requests. We conclude that the record demonstrates that Appeals Officer Kramer’s rejection of the offer-in-compromise was not an abuse of discretion.27 26(...continued) provides that the IRS may return the offer to the taxpayer. 27Petitioner alleges that he received from respondent a letter dated Jan. 19, 2006, which stated: “If your offer in compromise requires further actions, the Appeals employee will set a deadline for completion. These actions can include adding periods of liability or providing more financial information. If the deadline is not met, your offer in compromise will be returned.” Because respondent had already requested further financial information as of the date of the alleged letter, such language appears to be surplusage. Nonetheless, petitioner had been provided ample opportunity to submit the requested documents prior to Jan. 19, 2006, and petitioner could have but apparently (continued...)Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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