Wayne Allen Mootz - Page 32




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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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