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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.
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Last modified: November 10, 2007