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On April 5, 2004, petitioner submitted to Ms. Cochran a Form
656, Offer in Compromise, a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, one
letter explaining the offer amount, and three letters setting out
in detail petitioner’s position regarding the offer-in-
compromise. Petitioner’s letters included several exhibits.
The Form 656 indicated that petitioner was seeking an
effective tax administration offer-in-compromise based on public
policy and equity grounds. Petitioner offered to pay $129,230 to
compromise his outstanding tax liabilities for 1982 through
1996.7
On the Form 433-A, petitioner reported assets worth
approximately $420,000 and outstanding liabilities of
approximately $264,000. Petitioner also reported gross monthly
income of $21,728 and monthly living expenses of $14,382.
In the letter explaining the offer amount, petitioner stated
that he was offering to pay $129,230 “for all Hoyt-related years
to be paid in twenty-four months * * *. The amount accounts for
all the tax liability for 1982 through 1998 * * * and regular
interest through April 15, 1993. This offer assumes that no Tax
Motivated Transaction (TMT) interest is imposed”.
7 The details of petitioner’s 1986-96 tax years are not in
the record.
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