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opportunity to present information that he did not present in the
first section 6330 hearing. On remand, the case was assigned to
Settlement Officer John Vander Linden (Mr. Vander Linden).
In connection with the second section 6330 hearing,
petitioner provided respondent with Forms 433-A and 656 that
indicated that petitioner was requesting an offer-in-compromise
based only on effective tax administration.8 Petitioner offered
to compromise his outstanding tax liabilities not only for the
years subject to the proposed collection action, but also for
those arising from his 1994, 1995, and 1996 tax years.9
Petitioner offered to pay $85,344 to compromise an estimated
income tax liability of $228,000, inclusive of penalties and
interest. The $85,344 represented petitioner’s total income tax
liability, exclusive of penalties or interest. However,
petitioner’s offer-in-compromise did not set forth any grounds on
which an effective tax administration offer could be accepted.
The second section 6330 hearing was held on March 14, 2005.
Because the offer-in-compromise did not include any grounds for
accepting the offer, Mr. Vander Linden considered Ms. Merriam’s
8 Petitioner actually completed two offers-in-compromise,
one for 1991-95 and the other for 1996. Petitioner’s arguments
are not particular to one offer or the other, and respondent
considered both together. To avoid confusion, we refer to the
offers-in-compromise as a single offer.
9 At the time of the second sec. 6330 hearing, the taxes,
penalties, and interest for petitioner’s 1994, 1995, and 1996 tax
years were unassessed.
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