- 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 NextLast modified: November 10, 2007