Estate of Charles A. Lippitz, Deceased, Michael Lippitz, Administrator and Rhita S. Lippitz - Page 12




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               A qualified offer is defined in section 7430(g)(1) as a                
          written offer which:                                                        
                    (A) is made by the taxpayer to the United States                  
               during the qualified offer period;                                     
                    (B) specifies the offered amount of the taxpayer’s                
               liability (determined without regard to interest);                     
                    (C) is designated at the time it is made as a                     
               qualified offer for purposes of this section; and                      
                    (D) remains open during the period beginning on                   
               the date it is made and ending on the earliest of the                  
               date the offer is rejected, the date the trial begins,                 
               or the 90th day after the date the offer is made.                      
          Respondent argues that petitioner’s offers were not qualified               
          offers because they were not made during the qualified offer                
          period and because they do not specify the amount of petitioner’s           
          liability.8                                                                 
               1. Qualified Offer Period                                              
               Respondent argues that petitioner’s offers could not be a              
          qualified offer because they were not made within the qualified             
          offer period.  The qualified offer period begins on the date                
          respondent informs the taxpayer of a proposed deficiency and                
          “ending on the date which is 30 days before the date the case is            
          first set for trial.”  Sec. 7430(g).  Respondent interprets this            


               8 Respondent does not argue, and thus we do not consider,              
          that petitioner’s offer not be considered a qualified offer                 
          because petitioner failed to provide respondent with the                    
          substantiation and legal and factual arguments necessary for                
          informed consideration of petitioner’s claim for relief as                  
          required by sec. 301.7430-7(c)(4), Proced. & Admin. Regs.                   





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