Chi Wai - Page 5

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          offer was temporarily put on hold “pending a review of the ISO              
          rulings by National Office.”  Petitioner was later advised by               
          respondent’s offer specialist that “the Effective Tax                       
          Administration offer is not feasible as it is used [only] when              
          the net realizable equity [in the taxpayer’s assets] exceeds the            
          tax amount”, which was not the case here.                                   
               On May 1, 2003, petitioner submitted an amended offer-in-              
          compromise (amended OIC), which contained only doubt as to                  
          collectibility and effective tax administration (ETA) as reasons            
          for the offer, and again contained no dollar amount, which                  
          respondent treated as $1, and again rejected.  Petitioner then              
          filed a protest, and respondent’s settlement officer in general             
          appeals programs sustained the rejection of the amended OIC.                
               On May 20, 2004, respondent mailed to petitioner a Final               
          Notice - Notice of Intent to Levy and Notice of Your Right to a             
          Hearing, in response to which petitioner requested a hearing                
          (Appeals hearing).  In the request, petitioner asserted that                
          respondent’s rejection of petitioner’s OIC was an abuse of                  
          discretion.                                                                 
               On September 8, 2004, respondent advised petitioner that the           
          Appeals Office had sustained respondent’s Final Notice - Notice             
          of Intent to Levy and Notice of Your Right to a Hearing for the             









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