- 10 -
Accordingly, since the taxpayers have now been in
compliance for the two calendar quarters ended June 30,
2002 and September 30, 2002——and since the taxpayers
are currently in full compliance——I respectfully submit
the attached OIC’s.
Mr. Silverberg enclosed with Mr. Silverberg’s November 20,
2002 letter, inter alia, (1) completed Form 656, Offer in Compro-
mise (Form 656 or offer-in-compromise), that petitioner signed
and that was dated November 27, 2002 (petitioner’s November 27,
2002 offer-in-compromise) and (2) completed Form 433-A, Collec-
tion Information Statement for Wage Earners and Self-Employed
Individuals (Form 433-A), that petitioner signed and that was
dated November 27, 2002 (petitioner’s November 27, 2002 Form 433-
A).9
Respondent assigned an offer-in-compromise specialist (first
offer specialist) with the IRS offer-in-compromise unit to
investigate petitioner’s November 27, 2002 offer-in-compromise.
On January 12, 2004,10 Mr. Silverberg sent a letter to the
first offer specialist (Mr. Silverberg’s January 12, 2004 let-
ter). In that letter, Mr. Silverberg stated in pertinent part:
9The record does not indicate how Mr. Silverberg could have
enclosed with Mr. Silverberg’s November 20, 2002 letter Form 656
and Form 433-A that petitioner signed and that were dated Nov.
27, 2002, which was after the date of that letter. We note that
each of those documents was apparently signed by petitioner again
on Jan. 9, 2003.
10The record does not disclose what transpired with respect
to petitioner’s November 27, 2002 offer-in-compromise and peti-
tioner’s November 27, 2002 Form 433-A between the time respondent
assigned them to the first offer specialist and Jan. 12, 2004.
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