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files. Petitioner alleged that he had attempted to satisfy his
tax debt by making installment payments of $750 per month until
he became ill with cancer. Petitioner also alleged that the
collection activity was “premature” because his request for
“equitable relief” was still “under review”.4
By letter dated April 13, 2004, respondent’s settlement
officer scheduled a hearing on May 6, 2004. In the letter, the
settlement officer stated that if petitioner wished her to
consider collection alternatives, such as an offer-in-compromise,
he had to provide, within 10 days, certain documentation,
including completed collection information statements and a copy
of his filed 2003 Federal income tax return.
At petitioner’s request, the meeting was rescheduled and, by
agreement, the hearing was held by telephone on June 8, 2004.
Petitioner expressed a desire to submit an offer-in-compromise.
The settlement officer set a deadline of July 14, 2004, for
petitioner to submit a completed offer-in-compromise, as well as
a completed Form 433-A, Collection Information Statement for
Individuals, and Form 433-B, Collection Information Statement for
Businesses. At petitioner’s request, the settlement officer
extended this deadline to July 21, 2004.
4 It appears that petitioner’s reference to his request for
“equitable relief” refers to his Form 843, Claim for Refund and
Request for Abatement, filed on June 4, 2001, as discussed below.
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