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Form 433-A.2 The letter further stated that if Mr. Climan did
not “receive such documents by January 5, 2005, [he would] make a
determination based on the information contained in the case
file.” In addition to the letter, petitioner was provided all
the necessary forms with accompanying instructions on how to
complete an offer-in-compromise.
Petitioner failed to submit the offer or any financial
statement. As a result, no collection alternatives were
considered. Mr. Climan closed the case and determined the NFTL
was appropriate and in accordance with all procedural guidelines.
A further trial of this case was held in Los Angeles,
California, on March 23, 2005. At trial, petitioner reiterated
the issues presented during the section 6320 hearing. Petitioner
further asserted that the Appeals officer at that hearing had not
addressed the issues and concerns raised, but had attempted to
talk him into submitting another offer-in-compromise. Petitioner
testified he did not submit the offer-in-compromise because he
could not afford the $150 application fee. In addition, he
disagreed with Mr. Climan over whether the recorded lien would
remain in effect until the compromised balance of the tax
liability was completely paid.
2 Form 433-A, Collection Information Statement for Wage
Earners and Self Employed Individuals.
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Last modified: May 25, 2011