Douglas W. and Gail Caple - Page 9




                                        - 8 -                                         
               Mr. Caple also raised the issue of whether respondent had              
          abated interest and adjusted accuracy-related penalties with                
          respect to their accounts for 1993 and 1994.  Respondent had                
          previously agreed to abate interest and adjust the penalties                
          assessed against petitioners, pursuant to an agreement reached              
          between petitioners and respondent’s Milwaukee Problem Resolution           
          Office.  During the hearing, petitioners questioned whether                 
          respondent had, in fact, properly abated the interest and                   
          adjusted these penalties per their agreement.  Ms. Roberts                  
          reviewed petitioners’ account records during the hearing and                
          explained to them that these transcripts showed that the section            
          6662 penalties had been adjusted to zero and the interest had               
          been abated.  Per petitioners’ request, Ms. Roberts then sent a             
          copy of these account statements/transcripts to petitioners                 
          following the hearing.                                                      
               On June 29, 2004, petitioners submitted to respondent a Form           
          656, Offer in Compromise (OIC).  Petitioners offered to settle              
          the outstanding amount of tax owed by them as follows:  (1) A               
          payment of $100 (to be obtained from “checking accounts,                    
          investment accounts, and selling autos”10), (2) the application             

               9(...continued)                                                        
          Ashley was a college student and covered under their health                 
          insurance plan.                                                             
               10 Petitioners admitted, both during the hearing and when              
          this matter was heard by the Court, that in 1999, they purchased            
                                                             (continued...)           






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