- 8 - rely upon to reject petitioner’s offer-in-compromise. Petitioner’s contentions are unpersuasive. When requesting an offer-in-compromise, the taxpayer must provide complete and current financial information sufficient to enable the Appeals officer to adequately evaluate the offer. Sec. 301.7122-1(d)(2), Proced. & Admin. Regs. If the taxpayer fails to do so, the offer-in-compromise may be rejected. See, e.g., Shrier v. Commissioner, T.C. Memo. 2006-181; Picchiottino v. Commissioner, T.C. Memo. 2004-231; Willis v. Commissioner, T.C. Memo. 2003-302. The settlement officer did not abuse his discretion in finding that petitioner’s responses to requests for additional information were insufficient to permit a reasonable analysis of petitioner’s offer-in-compromise. The answers that petitioner provided to the settlement officer’s September 7, 2004, request for additional information were incomplete and insufficient to resolve legitimate questions raised by the settlement officer as to apparent discrepancies between petitioner’s reported financial information and the provisions of the marital settlement. For example, although the marital settlement indicated that Ms. Kerr had relinquished any interest in RMC, petitioner represented to the settlement officer, without supporting documentation, that RMC was wholly owned by Ms. Kerr. Petitioner has not credibly explained these inconsistencies or his failure to submit completePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011