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past non-compliance”, and respondent’s “analysis of * * *
[petitioner’s] current finances reveals that it will be highly
unlikely * * * [petitioner] will be able to remain in compliance
during the offer terms.” Therefore, respondent concluded “it
would not be in the best interest of the government”. In the
“REJECTION NARRATIVE” prepared in connection with the letter
informing petitioner of the rejection, dated August 10, 2004,
respondent noted that petitioner’s “reasonable collection
potential” was zero.
Shortly before rejecting the offer-in-compromise,
respondent, on July 22, 2004, filed a Notice of Federal Tax Lien
in Seminole County, Florida, with respect to petitioner’s 1990,
1993, 1994, 1996, 1997, 1999, 2000, and 2001, income tax
liabilities. Respondent then, on July 23, 2004, issued to
petitioner a corresponding Notice of Federal Tax Lien Filing and
Your Right to a Hearing Under IRC 6320 for the taxable years
1990, 1993, 1994, 2000, and 2001.2 In response, petitioner
2Taxable years 1996, 1997, and 1999, were not covered by
this notice because respondent had previously issued, on October
25, 2000, a Notice of Federal Tax Lien Filing and Your Right to a
Hearing under IRC 6320 for these years and petitioner had not
timely requested a hearing in response to that notice.
Respondent had also previously issued, on January 25, 1999, a
Final Notice of Intent to Levy and Notice of your Right to a
Hearing for taxable years 1993 and 1994, and petitioner had also
not timely requested a hearing in response to that notice.
Because petitioner’s requests for a hearing on the proposed levy
for 1993 and 1994, and the filed lien as to 1996, 1997, and 1999,
were filed late, petitioner was afforded an equivalent
(continued...)
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