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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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