Wayne Smith - Page 5




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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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