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petitioners’ representative, Terri A. Merriam (Ms. Merriam),
requested additional time to submit information. Ms. Cochran
extended petitioners’ deadline for producing information to March
31, 2004.
On March 31, 2004, petitioners 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 setting forth medical and retirement
considerations and explaining the offer amount, and three letters
setting out in detail petitioners’ position regarding the offer-
in-compromise. Petitioners’ letters included several exhibits.
The Form 656 indicated that petitioners were seeking an
offer-in-compromise based on either doubt as to collectibility
with special circumstances or effective tax administration.
Petitioners offered to pay $25,000 to compromise their
outstanding tax liabilities for 1981 through 1996, which they
estimated to be $255,254.
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