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various arguments regarding the appropriateness of an offer-in-
compromise.
On October 31, 2003, petitioners’ case was assigned to
Settlement Officer Linda Cochran (Ms. Cochran).
On February 13, 2004, petitioners submitted a letter (the
February 2004 letter) to Ms. Cochran. Petitioners described
their involvement in the Hoyt partnerships and made various
assertions regarding equity and public policy considerations.
Petitioners attached several exhibits to the February 2004
letter.
On March 8, 2004, Ms. Cochran sent petitioners a letter
scheduling a telephone section 6330 hearing for March 31, 2004.
Petitioners’ representative, Terri A. Merriam (Ms. Merriam),
requested that the hearing be delayed due to the number of Hoyt-
related cases her law firm was handling. Ms. Cochran did not
change the date of the hearing, but extended petitioners’
deadline for producing information to be considered to May 14,
2004.
On May 14, 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, and
three letters (the May 14, 2004 letters) explaining the offer
amount and other payment considerations and setting out in detail
petitioners’ position regarding the offer-in-compromise.
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Last modified: May 25, 2011