Jerry Joe Kerr - Page 4

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          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.                         





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