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On July 22, 2004, respondent received from petitioner Form
656, Offer in Compromise, and Form 433-A, but no Form 433-B. On
the Form 656, petitioner checked boxes indicating that he was
submitting his offer-in-compromise on the grounds of doubt as to
liability, doubt as to collectibility, and effective tax
administration. He offered “$12,500 * * * to be applied first to
pay’ts to my Social Security Account” in compromise of tax
liabilities totaling approximately $115,000 (including accrued
interest). Petitioner altered the standard terms of the Form 656
so as to eliminate the statement that he was signing under
penalties of perjury. As the basis for his offer-in-compromise,
petitioner alleged that respondent’s revenue agents had engaged
in “ministerial and managerial misconduct” by failing to review
more promptly the boxes of documents he had submitted on November
12, 1992, in response to the summons. He challenged his
underlying tax liabilities for 1987 through 1991.
Petitioner also altered the standard terms of the Form 433-A
so as to eliminate the statement that he was signing under
penalties of perjury. On the Form 433-A, petitioner failed to
disclose his ownership interest in certain real estate.
After evaluating petitioner’s offer-in-compromise and Form
433-A, by letter dated September 30, 2004, the settlement officer
requested additional information from petitioner, including a
Form 433-B for petitioner’s business, a copy of petitioner’s 2003
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