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Item 9 — Explanation of Circumstances
I am requesting an offer in compromise for the
reason(s) listed below:
Note: If you are requesting compromise based on
doubt as to liability, explain why you
don’t believe you owe the tax. If you
believe you have special circumstances
affecting your ability to fully pay the
amount due, explain your situation. You
may attach additional sheets if necessary.
* * *
Doubt as to collectibility. Taxpayer is a 70-year-
old sole practitioner with significant tax debts and
a declining law practice. This OIC accompanies
another OIC being made by Mr. Lloyd’s professional
corporation for its tax debts.[20] Based on a
detailed investigation just completed by the IRS,
this offer is 100% of the Reasonable Collection
Potential of Mr. Lloyd, and the P.C.’s offer is 100%
of its Reasonable Collection Potential.
Item 10 — Source of Funds
I/We shall obtain the funds to make this offer from
the following source(s):
Liquidation of assets and borrowing.
Petitioner’s June 24, 2005 Form 433-A contained several
sections identified as sections 1 through 9. In sections 1 and 2
of that form, petitioner provided the responses indicated to the
following questions:
6. List the dependents you can claim on your tax
return: * * *
20Mr. Silverberg did not enclose with Mr. Silverberg’s July
7, 2005 letter Form 656 with respect to petitioner’s professional
corporation.
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Last modified: March 27, 2008