Jerry Joe Kerr - Page 6

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               The settlement officer’s letter indicated that if the                  
          requested information were not provided by October 1, 2004,                 
          petitioner’s offer-in-compromise would be rejected.                         
               By letter dated September 29, 2004, petitioner provided a              
          minimal amount of documentation relating to his expenses, stating           
          that he paid for his expenses in cash.  Petitioner’s letter                 
          stated that his interest in “commercial vehicles”, as referenced            
          in the marital settlement, was limited to a single 1989 Ford                
          pickup, which he had already listed on his Form 433-A.                      
          Petitioner stated that two of the three companies referenced in             
          the marital settlement had closed down with no assets, and that             
          the other company, RMC, was wholly owned by his ex-wife.  He                
          provided no documentation of any sales or transfers of these                
          companies.  Petitioner stated that the Lake Winnebago, Missouri,            
          address was his “permanent mailing address” and that the Kansas             
          City “Euclid” address was where “I rent to live”; petitioner                
          stated that he had no copies of quitclaim deeds.  Finally,                  
          petitioner stated that the settlement officer’s request for                 
          financial statements referenced in the marital settlement was               
          “unclear” and that he had no copy of the statements.                        
               By notice of determination dated October 26, 2004 (the                 
          notice), the Appeals Office sustained the proposed levy.  An                
          attachment to the notice indicated, among other things, that                
          petitioner’s offer-in-compromise had been rejected because                  






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