Barry Shrier - Page 3

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          was employed and would submit an offer-in-compromise (OIC)                  
          relating to his income tax liabilities.  While petitioner was               
          unemployed, petitioner’s parents made several deposits into his             
          checking account (deposits).  In a letter dated February 27,                
          2004, respondent requested that petitioner provide an “affidavit            
          from * * * [petitioner’s] parents as to the amount of money they            
          gave him and * * * cancelled checks corresponding to the                    
          deposits.”  Respondent also asked petitioner to explain the car             
          lease expense.                                                              
               On March 23, 2004, petitioner submitted to respondent a Form           
          656, Offer in Compromise, in the amount of $2,000 based on doubt            
          as to collectibility (March OIC).  Petitioner attached an updated           
          Form 433-A to the March OIC but did not attach any additional               
          financial documents.  In a letter dated November 17, 2004,                  
          respondent requested additional financial information.  In a                
          second letter, also dated November 17, 2004, respondent requested           
          that petitioner “provide the documents specified on Form 433A               
          * * * [and] an affidavit from * * * [petitioner’s] parents as to            
          the amount of money they gave him.”  Respondent warned petitioner           
          that if the requested documents were not received by December 17,           
          2004, the March OIC would not be accepted.                                  
               On December 17, 2004, petitioner sent respondent an amended            
          OIC in the amount of $2,000 based on doubt as to collectibility             







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