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to meet before that or any other collection alternative could be
considered. During the May 3, 2005 conference, the settlement
officer and petitioner’s authorized representative discussed
collection alternatives, including the possibility of an offer-
in-compromise.
Upon receiving petitioner’s June 28, 2005 offer-in-compro-
mise, the settlement officer forwarded it to an offer examiner
for investigation. The settlement officer gave petitioner the
opportunity to respond to the recommendation of the offer exam-
iner and reviewed petitioner’s response to that recommendation.
While petitioner advanced certain contentions in petitioner’s
March 29, 2006 letter,11 petitioner did not provide any documents
or other information corroborating those contentions. The
settlement officer concluded that petitioner’s June 28, 2005
offer-in-compromise of $10,000 should be rejected because peti-
tioner had demonstrated ability to pay in full from his equity in
assets his Federal tax liabilities totaling between $32,449 and
$48,183.10.12 See supra note 7.
11As discussed above, the contentions that petitioner ad-
vanced in petitioner’s March 29, 2006 letter were that peti-
tioner’s brother paid for the real properties and that peti-
tioner’s inventory was “very dated”.
12As discussed above, petitioner offered $10,000 to compro-
mise not only petitioner’s unpaid 2001 income tax liability and
petitioner’s unpaid 2002 income tax liability but also certain
other outstanding Federal tax liabilities. See supra note 6 and
accompanying text and note 7.
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