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petitioners to schedule the hearing and asked petitioners to
tender the following items to Driver before the Hearing so that
she could explore a resolution: “Your proposal to resolve the
outstanding balance”; “Any documentation supporting your position
on any issue you wish to discuss”; “Completed and signed Form
433-A, Collection Information Statement for [Wage Earners and
Self-Employed] Individuals, along with supporting documentation”;
“Completed and signed Form 433-B, Collection Information
Statement for Businesses, along with supporting documentation.
This is required only if you own or have interest in a business”.
The letter stated that petitioners should provide the referenced
information to Driver by June 2, 2004. Pursuant to the request
of Gellner, who was also listed in a power of attorney as
petitioners’ representative, Driver extended the June 2, 2004,
date until June 30, 2004.
On June 29, 2004, petitioners submitted to Driver four
letters with accompanying exhibits; a signed and completed Form
656, Offer in Compromise, with an accompanying payment of a
related $150 fee; and a signed and completed Form 433-A with
supporting documentation. Through this submission, petitioners
offered to pay the Commissioner $11,552 to compromise what they
estimated was their $265,023 assessed and unassessed Federal
income tax liability (inclusive of additions to tax, penalties,
and interest) for 1984 through 1996. Each of the four letters
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Last modified: November 10, 2007