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penses, and that petitioner did not have any borrowing potential.
During the May 3, 2005 conference, the settlement officer
and petitioner’s authorized representative also discussed collec-
tion alternatives. The settlement officer indicated that it did
not appear that petitioner had sufficient income to fund an
installment agreement and that an offer-in-compromise might be
the best alternative. Petitioner’s authorized representative
informed the settlement officer that petitioner intended to ask
his mother for a loan in order to fund any offer-in-compromise,
but that he was uncertain whether petitioner’s mother would be
willing to do so. Petitioner’s authorized representative agreed
to contact the settlement officer by no later than May 20, 2005,
as to whether petitioner intended to submit an offer-in-compro-
mise.
On May 5, 2005, petitioner’s authorized representative sent
a letter to the settlement officer (May 5, 2005 letter). In that
letter, petitioner’s authorized representative stated in perti-
nent part:
I had a long talk with Mr. Mootz today. * * *
Enclosed are copies of the signed four (4) 941s for
2002. He indicates he filed them, without payment, in
late April.
* * * * * * *
As to judgments, there is a 2001/2002 Discover Card
judgment in Dubuque County Small Claims Court of about
$6,000.00 and a 2000 judgment by Tri-State Adjustment
for about $250.00. He also is currently being sued for
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Last modified: November 10, 2007