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hearing. Ms. Cochran extended petitioner’s deadline for
producing information to June 1, 2004.
On May 21, 2004, petitioner submitted to Ms. Cochran a
letter with 42 exhibits. On May 29, 2004, petitioner 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
three letters setting out in detail petitioner’s position
regarding the offer-in-compromise. Petitioner’s letters included
several exhibits not provided with the May 21, 2004, letter.
The Form 656 indicated that petitioner was seeking an offer-
in-compromise based on either doubt as to collectibility with
special circumstances or effective tax administration.
Petitioner offered to pay $120,500 to compromise his outstanding
tax liabilities for 1981 through 1996. Petitioner estimated that
his outstanding tax liabilities for 1981 through 1986, 1988, and
1992 only were $480,034.
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