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On December 14, 2004, petitioner participated in a face-to-
face hearing with a settlement officer. Petitioner and the
settlement officer also communicated through correspondence. By
letter dated January 25, 2005, the settlement officer informed
petitioner that she was sustaining the previous rejection of
petitioner’s most recent offer-in-compromise.5 The settlement
officer offered petitioner the opportunity to enter into an
installment agreement requiring a monthly payment of $1,215.
Petitioner rejected the settlement officer’s offer, complaining
that the amount was too high. By letter dated February 10, 2005,
the settlement officer provided petitioner a copy of his
previously submitted Form 433-A and a blank Form 433-A and
informed petitioner that he had until February 25, 2005, to
submit any additional information to assist her in making her
determination.
By letter dated February 24, 2005, petitioner again
requested relief from the additions to tax and interest that had
been assessed for 2000 and 2001 because of his precarious job and
financial situations. Petitioner also submitted an updated Form
433-A showing $13,000 in assets ($2,000 in cash and $11,000 in
investments), $18,500 in credit card debt, and monthly net income
of approximately $355.
5We assume that this was a rejection of petitioner’s third
offer-in-compromise (submitted in March 2004).
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