- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011