Leonard O. Parker, Jr. - Page 7

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          the assessment of his 1994 tax liability on October 9, 1995.                
          Collection alternatives were also discussed at length.                      
          Petitioner indicated he wished to enter into an offer-in-                   
          compromise or an installment agreement as a means of settling the           
          tax liability.                                                              
               Petitioner and Mr. Climan discussed petitioner’s current               
          financial circumstances.  Petitioner stated he received State               
          assistance of $221 monthly, and $149 monthly in food stamps.  He            
          further asserted he had no assets.  The parties’ discussion                 
          focused upon the possible use of an offer-in-compromise.                    
               As a result of his alleged limited resources, petitioner               
          informed Mr. Climan he was not financially able to pay the $150             
          offer-in-compromise application fee.  Mr. Climan told petitioner            
          that if his representations concerning his financial position               
          were true, he would qualify for the application fee waiver.                 
          Further, Mr. Climan assured petitioner if everything petitioner             
          stated regarding his current financial position was true, if                
          petitioner “put an offer-in-compromise for $100 on [Mr. Climan’s]           
          desk [he] would make it fly like a bird.”                                   
               At the end of the hearing, Mr. Climan gave petitioner a                
          previously prepared letter which stated petitioner had until                
          January 5, 2005, to submit the Form 656 Offer-in-Compromise and             

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