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offer to compromise their 1981 through 1998 Federal income tax
liability due to doubt as to collectibility with special
circumstances and to promote effective tax administration.
Petitioners contended that Appeals should accept their offer as a
matter of equity and public policy. Petitioners stated that it
had taken a long time to resolve the Hoyt partnership cases and
noted that Hoyt had been convicted on the criminal charges. The
second issue concerned an interest abatement case under section
6404(e) that petitioners mistakenly stated they had pending with
respondent.5 Petitioners stated that the interest abatement case
related to the same years at issue here and that the proposed
levy should be rejected because that case was pending.6
On May 7, 2004, petitioners tendered to Cochran on Form 656,
Offer in Compromise, a written offer to pay $35,000 to compromise
their estimated approximately $575,000 liability. Petitioners
supplemented their offer with a completed Form 433-A, Collection
Information Statement for Wage Earners and Self-Employed
Individuals, four letters totaling approximately 80 pages, and
volumes of documents. The Form 433-A reported that petitioners
5 While petitioners stated that they had the interest
abatement case pending in this Court, they never petitioned this
Court with respect to the interest abatement issue.
6 Petitioner Mary Catlow also requested relief under sec.
6015(b) and (f). In that Mary Catlow later agreed that she was
not entitled to her requested relief, petitioners do not advance
that claim in this proceeding.
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Last modified: May 25, 2011