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date respondent accepted the offer. The letter warned petitioner
that he needed to pay his remaining 2002 tax liability of
$71,984.36 within 30 days “to prevent termination of * * * [his]
Offer In Compromise.” The letter stated that if petitioner did
not comply, respondent would terminate the OIC and would
reinstate the original amount of the compromised liability,
reduced for the payment petitioner had already made.
That letter apparently never reached petitioner and was
returned to respondent by the Postal Service. Respondent sent a
nearly identical letter containing the same warnings to
petitioner at his new address on December 10, 2003. By that
time, because of the accrual of interest and penalties,
petitioner’s 2002 liability had increased to $72,683.54.
Petitioner does not contend that he did not receive the December
10 letter. Petitioner did not pay his 2002 tax liability within
30 days of the December 10 letter or otherwise reply to the
letter.
Petitioner received a letter from respondent dated February
11, 2004. In that letter, respondent declared petitioner in
default of the OIC and stated that “arrangements to compromise
the liability are terminated.”
Respondent applied petitioner’s payment on the OIC to his
previously compromised liabilities. This left balances owing for
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Last modified: May 25, 2011