Bernard A. Kansky - Page 10

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            petitioner had failed to comply with her requests to verify his                             
            health claims, he did not qualify for an offer-in-compromise on                             
            the basis of effective tax administration.  Accordingly, no                                 
            viable collection alternative having been proposed, the                                     
            settlement officer sustained respondent’s collection action.                                
                  In his petition in docket No. 24528-04L, petitioner                                   
            challenges respondent’s collection action.  The petition states                             
            that “The only years which should be in question are the tax                                
            years 1987, 1990 and 1991” and adds:                                                        
                  The only reason that the tax years 1987, 1990 and 1991                                
                  remain unpaid is that despite the taxpayer’s earmarking                               
                  funds for the years due, the IRS nevertheless applied                                 
                  those payments instead, in such a haphazard manner so                                 
                  as to leave the oldest years ongoing and outstanding,                                 
                  thereby increasing the amount of compounding interest                                 
                  for even greater and extended periods of time.                                        
                  In his petition, petitioner alleges that he sustained an                              
            overall net loss for 1987 through 1991 and that loss carrybacks                             
            and carryforwards should eliminate any Federal income tax for                               
            these years.  He claims to have already paid the IRS $27,000,                               
            representing 36 installment payments of $750 each.                                          







                  5(...continued)                                                                       
            sale value” of $508,880, reduced by a $123,096 encumbrance on the                           
            real estate and further reduced by 50 percent to reflect                                    
            petitioner’s joint ownership with his wife.                                                 





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