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29, 2004 offer-in-compromise, petitioner provided the responses
indicated to the following questions:
Item 5 — To: Commissioner of Internal Revenue Service
I/We * * * submit this offer to compromise the tax
liabilities plus any interest, penalties, additions to
tax, and additional amounts required by law (tax
liability) for the tax type and period marked below:
* * *
: 1040/1120 Income Tax — Year(s) 1990, 1991, 1992,
1994, 1996, 1997, 2002
* * * * * * *
: Trust Fund Recovery Penalty as a responsible
person of (enter corporate name) Henry M. Lloyd
PC, for failure to pay withholding and Federal
Insurance Contributions Act Taxes (Social Security
taxes), for period(s) ending 9703.
9 Other Federal Tax(es) [specify type(s) and
period(s)]
In items 6 and 7 of petitioner’s September 29, 2004 offer-
in-compromise, petitioner provided the responses indicated to the
following questions:
15(...continued)
that was dated Sept. 29, 2004. We do not know whether Form 656
that petitioner signed and that was dated Sept. 29, 2004, and
that Mr. Silverberg enclosed with Mr. Silverberg’s October 1,
2004 letter was the “last amended F656” referred to in the first
offer specialist’s September 6, 2004 letter. See supra note 13
and accompanying text.
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