- 4 - had reasonable cause for his failure to pay the taxes; (2) the Internal Revenue Service (IRS) should have accepted his offer-in- compromise based on doubt as to collectibility because of the possibility of discharge of his taxes in the event he filed for bankruptcy; and (3) alternatively, in the event his offer-in- compromise was not accepted, the IRS should have allowed him to pay his tax liability in installments. Petitioner’s section 6330 hearing was conducted by means of a face-to-face meeting, correspondence, and telephone conversations with a settlement officer in respondent’s Appeals Office (the settlement officer). On November 2, 2004, the IRS received petitioner’s offer to compromise his total tax liability for 1997, 1998, 1999, 2000, and 2001 for $70,000.7 On December 8, 2005, following petitioner’s submission of additional information in response to requests by respondent, the settlement officer advised petitioner that petitioner was ineligible for an offer- in-compromise because petitioner had the ability to fully pay his income tax liability over 48 months. On December 22, 2005, the settlement officer wrote a letter to petitioner explaining, among other things: (1) That petitioner had not as yet provided any 6(...continued) actually are to additions to tax under sec. 6651(a)(1) and (2) and sec. 6654. References in this opinion to additions to tax relate to one or more, as appropriate. Petitioner does not seek abatement of interest. 7Tax year 2001 is not at issue herein.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007