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the hearing requests, prepared by petitioner’s representative,
stated that petitioner was working on an offer-in-compromise
(OIC) to resolve his tax liability.
By letter dated October 11, 2005, respondent’s settlement
officer informed petitioner that his request for a hearing was
timely and scheduled a telephone conference for November 1, 2005.
In response to petitioner’s mention of an OIC in the hearing
request, the settlement officer also requested a completed Form
433-A, with required attachments, copies of petitioner’s 2004
Federal and State income tax returns, and a Form 656, Offer in
Compromise, with the required processing fee. The settlement
officer asked that this information be submitted within 14 days
to allow time for review before the telephone conference.
Petitioner never forwarded an OIC, the necessary financial
information, or any other documentation.
Neither petitioner, nor his representative, ever confirmed
the hearing or otherwise corresponded with the settlement officer
with respect to the scheduled hearing. Nevertheless, a telephone
conference in which petitioner’s representative participated was
conducted on November 1, 2005, as initially scheduled. On
December 2, 2005, the settlement officer issued a determination
sustaining the Federal tax lien filing.
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Last modified: November 10, 2007