- 5 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011