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pertinent part:
I have received the results of investigation of your
Offer in Compromise. The examiner’s recommendation was
that the offer should not be accepted because Net
Realizable Equity in assets is substantially greater
than the amount you offered as set forth below:
ASSET/EQUITY TABLE
OFFER DEPOSIT -0-
CASH/BK ACCTS 100
LIFE INS -0-
PENS/IRA/401(k) -0-
REAL PROP (2) 85,400
PERS PROP -0-
TOOLS/EQUP -0-
1991 CADILLAC 1,000
1993 GMC 2,000
BUS INVENTORY 29,608
ACCTS REC 3,500
TOTAL 121,608
If you wish to appeal the examiner’s findings, please
submit information no later than March 31, 2006 to show
the areas of disagreement and I will schedule a confer-
ence to discuss the examiner’s findings and any addi-
tional information you submit.
If the offer cannot be recommended for acceptance, we
will discuss other collection alternatives. [Repro-
duced literally.]
On March 29, 2006, petitioner sent a letter to the settle-
ment officer (petitioner’s March 29, 2006 letter). In that
letter, petitioner stated in pertinent part:
I have worked with you and your people for the past
four years. In that time you have levied against me
and taken about $3,000 dollars. Also I have paid over
$3,000 dollars in legal fees. From the very start your
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Last modified: November 10, 2007