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liability. By letter to petitioner dated September 7, 2004, the
Appeals officer advised that he needed additional information in
order to evaluate the offer-in-compromise on the basis of doubt
as to collectability. The settlement officer requested, among
other things, substantiation of the living expenses petitioner
had claimed on his Form 433-A. In addition, referring to
provisions of the marital settlement, the settlement officer
requested additional information, including the following:
1. Descriptions and values of the “commercial vehicles”
that the marital settlement indicated Ms. Kerr had relinquished
to petitioner.
2. With respect to the three companies that the marital
settlement indicated had been retained by petitioner, an
explanation of the current status of these companies, including
documentation of any sales or transfers of the companies’ assets.
3. Information about the real properties that, according to
the marital settlement, petitioner had quitclaimed to Ms. Kerr.
The settlement officer requested an explanation as to why
petitioner had since used, at different times, the Lake
Winnebago, Missouri, address and the Kansas City “Euclid” address
as his home address on correspondence with the IRS.
4. A copy of the income and expense statements and
financial statements referenced in the marital settlement.
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Last modified: May 25, 2011