- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008