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letter, Mr. Silverberg stated in pertinent part:
Mr. Lloyd has been dealing, through me as his
representative, with the Collections Division in
Fairfax, Virginia, and with your [first] Offer Special-
ist * * *. Mr. Lloyd has submitted Form 656 proposing
Offers in Compromise to settle these liabilities due to
doubt as to collectibility. Throughout a period ex-
ceeding one year, * * * [the first offer specialist]
has evaluated Mr. Lloyd’s Reasonable Collection Poten-
tial (RCP) and has performed an extensive investigation
of his assets, his income potential and his costs of
living.
After conducting his investigation, * * * [the
first offer specialist] and Mr. Lloyd reached an agree-
ment in principle, whereby Mr. Lloyd submitted an
Amended Form 656 in October, 2004, offering to pay
$139,707 over an installment period of 84 months. This
amount is 100 per cent of the RCP finally determined by
* * * [the first offer specialist]. For reasons which
Mr. Lloyd and I do not understand, this OIC was treated
by the Service as withdrawn at the last minute, rather
than accepted. We were given the explanation that some
out-of-compliance situation had been identified, and
that the OIC could not be considered until Mr. Lloyd
was back in compliance. Upon investigation, it was
determined he was not out-of-compliance. However, no
action was taken on his OIC. Instead, you have issued
notices indicating you intend to levy.
Mr. Lloyd is still willing to agree to the October
2004 OIC which is 100 per cent of his RCP. He believes
that he and the IRS have an agreement. However, for
reasons unknown to us the Collections Division was
unwilling to indicate its acceptance by signing off on
the OIC.
Too much time has been invested by Mr. Lloyd and
by the Service to waste it by treating the OIC as
withdrawn. The agreement should be signed and Mr.
Lloyd should begin making the monthly installments
which will put this matter to rest.
Mr. Lloyd and I hereby request an opportunity to
appear in person to discuss this matter at a CDP hear-
ing. Our hope is that an agreed OIC will result from
that hearing. * * *
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Last modified: March 27, 2008