- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011