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Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid 2002 liability.
On November 20, 2002, Kenneth H. Silverberg (Mr.
Silverberg), petitioner’s authorized representative, sent a
letter (Mr. Silverberg’s November 20, 2002 letter) to a manager
in the IRS’s offer-in-compromise unit (IRS offer-in-compromise
unit). In that letter, Mr. Silverberg stated in pertinent part:
RE: Henry M. Lloyd * * *
Henry M. Lloyd PC * * *
Attached Offers in Compromise
* * * * * * *
Pursuant to your letters of November 5, 2002, and
on behalf of my clients identified above, I respect-
fully submit copies of two Offers In Compromise, at-
tached as completed Forms 656, along with supporting
Forms 433-A and 433-B, and additional documentation
which was provided by your Revenue Officer * * * [first
revenue officer].
We were advised by your Process Examiners that
this OIC as previously submitted to you on October 28,
2002, was acceptable in form other than the fact that
certain previous-period returns were not on file with
the IRS (see attached statement by the taxpayer ex-
plaining why these returns were not required, and
attaching copies of returns as recently filed) and also
that an obsolete version of Form 433-A and 433-B was
used (the obsolete forms have been replaced with appro-
priate forms, revision date 5/2001).
8(...continued)
ties for 1990, 1991, and 1992, petitioner’s unpaid 1994 liabil-
ity, petitioner’s unpaid 1996 liability, petitioner’s unpaid 1997
liability, and petitioner’s unpaid 2002 liability as petitioner’s
unpaid liabilities for 1990, 1991, 1992, 1994, 1996, 1997, and
2002.
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