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respondent’s Notice of Intent to Levy on the grounds that the
“collection by levy is inappropriate as [I] intend to submit an
offer in compromise to resolve the tax liability soon.”
Offer-In-Compromise
As contemplated in his request for a hearing, an offer-in-
compromise (OIC) was submitted on petitioner’s behalf by the
Kansas City Tax Clinic on September 30, 2004. Petitioner offered
to pay a total of $9,407.60 in 24 monthly payments of $391.98, to
compromise his outstanding total tax liabilities, including any
interest, penalties, and additions to tax with respect to the
taxable years at issue.
A document entitled “Explanation of Special Circumstances”
(Explanation) was attached to petitioner’s OIC. In this
Explanation, petitioner stated that when he was retired from AT&T
in 1998 as the result of a corporate downsizing, his pension
account with Bank of America had a value of approximately
$400,000. At some time after his separation from AT&T,
petitioner bifurcated this pension account, placing about one-
half of its total value into a new, separate retirement account,
also with Bank of America. The Explanation also stated that a
combination of his taking several distributions from both of his
Bank of America accounts, along with poor market factors, had
resulted in a total depletion of one of the two Bank of America
accounts.
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