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to the letter, only petitioners’ 1997-99 income tax liabilities
were at issue.
The record does not indicate whether the parties met on June
3, 2004. From June 16 through December 3, 2004, however,
petitioners’ counsel and respondent’s counsel exchanged several
letters and extensive documentation relating to petitioners’
offer-in-compromise. By letter dated November 8, 2004,
respondent informed petitioners’ counsel that petitioners must
increase their offer-in-compromise by the amount of the
prospective bankruptcy distribution in order to protect
respondent’s interest in the distribution proceeds. By letter
dated November 22, 2004, petitioners’ counsel objected to an
increase in the offer-in-compromise and instead offered to
execute an agreement assigning petitioners’ future rights to the
prospective distribution to respondent.
On January 4, 2005, respondent rejected petitioners’ offer-
in-compromise and issued a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) sustaining the proposed levy action with respect
to petitioners’ 1997, 1998, and 1999 income tax liabilities.6 On
6Attached to the notice of determination in the record are
two rejection letters from respondent. One letter rejects the
offer-in-compromise for the years 1997, 1998, and 1999. The
other rejects the offer for the quarters ending December 1998
through June 2001. However, the notice of determination covers
only the income tax liabilities for years 1997, 1998, and 1999.
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