Jerry Joe Kerr - Page 8

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          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 complete           






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