- 7 - 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 2003Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011