Stuart Hult - Page 5




                                        - 5 -                                         
               From representations made in petitioner’s July 25 letter, it           
          appears that along with the letter, petitioner submitted a new              
          offer-in-compromise (the 2003 offer).3  According to the 2003               
          offer, petitioner proposed to satisfy his outstanding tax                   
          liabilities with a cash offer of $1,000 payable within 90 days              
          from the date that respondent accepted it.  As in the case of the           
          2000 offer, the 2003 offer was based upon “doubt as to                      
          collectability”.                                                            
               In a letter dated August 6, 2003, from Mr. Barry, petitioner           
          was asked to supplement some of his responses, and once again,              
          Mr. Barry requested information relating to the 2002 income of              
          petitioner’s wife.  According to Mr. Barry, the income of                   
          petitioner’s wife was “relevant to * * * petitioner’s offer”.               
          Elsewhere in the letter, petitioner was advised that “for the IRS           
          to accept an offer based upon doubt as to collectability, the               
          amount offered must be at least equal to the taxpayer’s net                 
          equity in assets”.  On the basis of an analysis of petitioner’s             
          financial status included in the letter, Mr. Barry concluded that           
          petitioner’s “current offer does not appear to meet that                    
          criterion”.  It cannot be determined whether references to                  
          petitioner’s “offer” or “current offer” made in the August 6                


               3 The exact date that the 2003 offer was submitted cannot be           
          determined.  It is referenced in petitioner’s July 25, 2003,                
          letter to Mr. Barry but dated July 27, 2003.  Mr. Barry                     
          acknowledged receipt of the 2003 offer on Aug. 25, 2003.                    





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007