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While Ms. Cochran normally required documents to be submitted
before the section 6330 hearing, she extended petitioner’s
deadline for producing information to April 9, 2004.
On April 9, 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, one letter explaining the offer amount and other
payment considerations, and three letters setting out in detail
petitioners’ position regarding the offer-in-compromise.
Petitioners’ letters included several exhibits.
The Form 656 indicated that petitioners were seeking an
offer-in-compromise based alternatively on doubt as to
collectibility with special circumstances or effective tax
administration. Petitioners offered to pay $60,400 to compromise
their outstanding tax liability for 1981 through 1996. At the
time of the section 6330 hearing, $345,145 had been assessed
against petitioners with respect to their 1981 through 1996 tax
years.
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