- 4 - petitioner proposed to pay his 1992 taxes with $10,000 up front and $1,000 per month thereafter. On June 21, 2004, respondent’s settlement officer held a face-to-face hearing with petitioner and his representative.3 On July 6, 2004, the Appeals Office received from petitioner Form 656, Offer in Compromise, wherein petitioner offered to compromise his 1992 income tax liability for $7,500. Petitioner’s Form 656 indicated that the offer-in-compromise was predicated on doubt as to liability and doubt as to collectability. Also on July 6, 2004, petitioner submitted to respondent Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals. On the Form 433-A, petitioner reported that his only income was a pension of $2,201 per month and that he had monthly living expenses of $2,144. None of the required documentation was attached to the Form 433- A. The last page of the Form 433-A admitted into evidence contains the settlement officer’s handwritten calculations, which show, without elaboration, the sum of $9,558.16. By letter dated July 16, 2004, the settlement officer advised petitioner that, because of the previous Tax Court decision adjudicating his 1992 income tax liability, his offer- in-compromise could be not considered on the basis of doubt as to 3 Apparently, at this hearing petitioner made no mention of his previous installment agreement request; it is unclear that the settlement officer was aware of it at the time.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011