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people told me we could work out a reasonable compro-
mise. Now you refuse my offer. * * *
* * * * * * *
The property you have listed was paid for solely by my
brother.
My inventory is very dated * * *
In view of these events , I do not feel I was treated
fairly. [Reproduced literally.]
Petitioner did not provide any documents or other information
corroborating the contentions advanced in petitioner’s March 29,
2006 letter that petitioner’s brother paid for the real proper-
ties and that petitioner’s inventory was “very dated”.
On March 30, 2006, the settlement officer telephoned (March
30, 2006 telephone call) petitioner’s authorized representative
and informed him (1) that petitioner’s June 28, 2005 offer-in-
compromise of $10,000 was not adequate and would not be accepted
to resolve the various Federal tax liabilities of petitioner for
various taxable years, including petitioner’s unpaid 2001 income
tax liability and petitioner’s unpaid 2002 income tax liability,7
7The “Rejection or Withdrawal Memorandum” dated Mar. 30,
2006, that the settlement officer prepared with respect to
petitioner’s June 28, 2005 offer-in-compromise showed that
petitioner had total outstanding Federal tax liabilities of
$48,183.10. The “Appeals Transmittal and Case Memo” dated Apr.
19, 2006, that the settlement officer prepared with respect to
that offer-in-compromise showed that petitioner had total out-
standing Federal tax liabilities of $32,449. The Court is unable
to reconcile the difference between the respective outstanding
Federal tax liabilities shown in the settlement officer’s “Rejec-
tion or Withdrawal Memorandum” and the settlement officer’s
(continued...)
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