- 6 - claim any of the Hoyt-related expenses claimed on his returns; (2) agreed that the higher rate of interest applicable to tax- motivated transactions will apply; and (3) waived any claim for the abatement of interest. Petitioner did not accept the settlement offer. On March 10, 2003, respondent sent petitioner a Final Notice of Intent to Levy and Notice of Your Right to a Hearing relating to 1991, 1992, and 1993. On April 8, 2003, petitioner submitted a Form 12153, Request for a Collection Due Process Hearing. Petitioner indicated he would pursue offers-in-compromise based on doubt as to collectibility and effective tax administration and would provide financial information upon request. On January 21, 2004, a section 6330 hearing was held by phone between Settlement Officer Kathleen Lee (Ms. Lee) and Terri A. Merriam (Ms. Merriam), petitioner’s attorney. Ms. Merriam indicated that petitioner would most likely be able to pay the tax in full, and thus he wished to pursue only an effective tax administration offer-in-compromise. However, Ms. Merriam did not provide Ms. Lee with Form 656, Offer in Compromise, or with Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals. On February 4, 2004, Ms. Merriam sent Ms. Lee a letter indicating that petitioner had not yet completed a Form 433-A, but one would be obtained “shortly”. Because petitioner wouldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011