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With the filing of her OIC, petitioner did not make any
payment to respondent, but petitioner did offer to pay the
$258,000 within 90 days of respondent’s acceptance of her OIC.3
Petitioner planned to sell assets in order to obtain the
$258,000.
On April 15, 2004, petitioner paid respondent the final
$79,166 she owed relating to her criminal conviction, and
petitioner asked that the $79,166 be credited toward the $258,000
she would owe under the pending OIC.
In connection with the Appeals Office’s consideration of
petitioner’s OIC, a number of communications about petitioner
occurred among respondent’s Appeals officer, an offer specialist
assigned to work on petitioner’s OIC, and two of respondent’s
revenue officers, one of whom worked in California and one of
whom worked in Oregon. Before petitioner’s CDP hearing with
respondent’s Appeals officer, both of these revenue officers had
been involved in attempting to collect petitioner’s outstanding
taxes for the years in issue. The communications between
respondent’s Appeals officer and the offer specialist, on the one
hand, and respondent’s two revenue officers, on the other,
3 By Mar. 11, 2004, petitioner had paid respondent $170,834
due as a result of the criminal conviction relating to her 1992
through 1995 Federal income taxes, which amount is separate from
the $258,000 petitioner offered to pay respondent under the
offer-in-compromise.
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Last modified: May 25, 2011