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Item 5 — To: Commissioner of Internal Revenue Ser-
vice
I/We * * * submit this offer to compromise the tax
liabilities plus any interest, penalties, additions
to tax, and additional amounts required by law (tax
liability) for the tax type and period marked below:
* * *
: 1040/1120 Income Tax — Year(s) 2000 to 2002, in-
clusive
: 941 Employer’s Quarterly Federal Tax Return —
Quarterly period(s) 1998 to 2001, inclusive
: 940 Employer’s Annual Federal Unemployment (FUTA)
Tax Return — Year(s) 1998 to 2001, inclusive[6]
In items 6 and 7 of petitioner’s June 28, 2005 offer-in-
compromise, petitioner provided the responses indicated to the
following questions:
Item 6 — I/We submit this offer for the reason(s)
checked below:
9 Doubt as to Liability — “I do not believe I owe
this tax.” You must include a detailed explana-
tion of the reason(s) why you believe you do not
owe the tax in Item 9.
: Doubt as to Collectibility — “I have insufficient
assets and income to pay the full amount.” You
must include a complete Collection Information
Statement, Form 433-A and/or Form 433-B.
6In item 5 of petitioner’s June 28, 2005 offer-in-compro-
mise, petitioner offered to compromise his respective Federal tax
liabilities for certain taxable years that the settlement officer
did not show as petitioner’s liabilities in his “Rejection or
Withdrawal Memorandum” discussed infra note 7. In addition, as
also discussed infra note 7, in his “Rejection or Withdrawal
Memorandum”, the settlement officer showed as petitioner’s
liabilities his respective Federal tax liabilities for certain
taxable years that petitioner did not offer to compromise in item
5 of petitioner’s June 28, 2005 offer-in-compromise.
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Last modified: November 10, 2007