- 4 - additional refund checks, petitioner did not make any further payments to Mr. Rudolph because he knew that Mr. Rudolph was then under investigation by the authorities. Apparently so was petitioner. In December 1999, petitioner pleaded guilty to one count of violating 18 U.S.C. sec. 201(c)(1)(A) (bribery of public officials), and the corresponding judgment was entered in April 2000. Petitioner was sentenced to 3 months’ home detention and 3 years’ probation; petitioner also agreed--as a condition of his probation--to cooperate with the IRS in the collection of “all outstanding taxes, interest, and penalties.” In April 2005, respondent sent petitioner a Form 4549, Income Tax Examination Changes, showing the proposed changes to petitioner’s income tax returns for 1992, 1993, and 1994. The proposed changes resulted in a total balance due, including interest and civil fraud penalties under section 6663, of $39,645.20.3 Petitioner objected to imposition of the fraud penalties but agreed to the adjustments related to the underpayments of tax. While his objection to the fraud penalties was being processed, petitioner submitted a Form 656, Offer in Compromise (OIC), for all 3 tax years. In the OIC, petitioner offered to 3 The interest owed was calculated only to May 25, 2005, and the penalty calculations were made only to Apr. 25, 2005.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007