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the hearing be delayed because of the number of Hoyt-related
cases her law firm was handling. Ms. Cochran did not change the
date of the hearing, but she extended petitioner’s deadline for
producing information to be considered to May 14, 2004.
On May 14, 2004, petitioner submitted to Ms. Cochran a Form
656, Offer in Compromise, a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, one
letter explaining the offer amount and other payment
considerations, and three letters setting out in detail
petitioner’s position regarding the offer-in-compromise.
Petitioner’s letters included several exhibits.
The Form 656 indicated that petitioner was seeking an offer-
in-compromise based on either doubt as to collectibility with
special circumstances or effective tax administration.
Petitioner offered to pay $157,824 to compromise his outstanding
tax liabilities for 1982 through 1996. On July 21, 2004,
petitioner submitted an “Amendment of Form 656”, seeking to
include his 2001 tax year as part of the offer-in-compromise.8
8 While the notice of determination covered petitioner’s
1997 tax year, it does not appear that he sought to include 1997
in his offer-in-compromise.
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