James O. Jondahl - Page 6

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               A qualified offer is defined in section 7430(g)(1) as a                
          written offer which:                                                        
                    (A) is made by the taxpayer to the United States                  
               during the qualified offer period;                                     
                    (B) specifies the offered amount of the taxpayer’s                
               liability (determined without regard to interest);                     
                    (C) is designated at the time it is made as a                     
               qualified offer for purposes of this section; and                      
                    (D) remains open during the period beginning on                   
               the date it is made and ending on the earliest of the                  
               date the offer is rejected, the date the trial begins,                 
               or the 90th day after the date the offer is made.                      
          Section 301.7430-7(c)(3), Proced. & Admin. Regs., provides that a           
          qualified offer “specifies the offered amount if it clearly                 
          specifies the amount for the liability of the taxpayer * * * .              
          The offer may be a specific dollar amount of the total liability            
          or a percentage of the adjustments at issue in the proceeding at            
          the time the offer is made.”  Additionally, “This amount must be            
          with respect to all of the adjustments at issue in the                      
          administrative or court proceeding at the time the offer is made            
          and only those adjustments.”  Id.  Finally, the specified amount            
          “must be an amount, the acceptance of which by the United States            
          will fully resolve the taxpayer’s liability, and only that                  
          liability * * * for the type or types of tax and the taxable year           
          or years at issue in the proceeding.”  Id.                                  
               Respondent argues that petitioner’s offer does not clearly             
          specify the offered amount for petitioner’s liability because it            






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