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petitioner to submit an offer-in-compromise and requested that
petitioner return any such offer directly to the settlement
officer by no later than July 6, 2005.
On June 29, 2005, petitioner’s authorized representative
sent a letter to the settlement officer (June 29, 2005 letter).
In that letter, petitioner’s authorized representative stated in
pertinent part:
Enclosed is Mr. Mootz’s signed Offer In Compromise and
Mr. Mootz’s check for $150.00 for the processing fee.
Since Wayne originally attempted to settle this matter
in 2003, he has made substantial payments to the I.R.S.
As to Wayne’s interest in the two parcels of real
estate, it should be noted he only owns a one half (½)
interest. Arguably, the value of an undivided one half
(½) interest to a third party would be limited at best.
While his brother owns the other one half interest,
Wayne also owes him a substantial sum for expenses,
etc. paid by his brother in connection with the real
estate. While this sum has not been quantified by a
note and/or mortgage Wayne contends it is a legal
obligation. [Reproduced literally.]
Petitioner’s authorized representative submitted with his
June 29, 2005 letter petitioner’s offer-in-compromise dated June
28, 2005 (petitioner’s June 28, 2005 offer-in-compromise).5 In
item 5 of petitioner’s June 28, 2005 offer-in-compromise, peti-
tioner provided the responses indicated to the following ques-
tions:
5The copy of petitioner’s June 28, 2005 offer-in-compromise
that is in the record does not appear to be complete. Item 8
appears to be missing.
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Last modified: November 10, 2007