- 30 -
that you provided. You will be contacted by an offer
specialist in the near future. I will maintain juris-
diction of the case and all final decisions regarding
this matter will be rendered by appeals. If you have
any further questions regarding this correspondence, do
not hesitate to call me.
On August 2, 2005, the settlement officer forwarded peti-
tioner’s June 24, 2005 offer-in-compromise and petitioner’s June
24, 2005 Form 433-A to the IRS offer-in-compromise unit.
Around August 4, 2005, respondent assigned an offer-in-
compromise specialist other than the first offer specialist to
investigate petitioner’s June 24, 2005 offer-in-compromise and
petitioner’s June 24, 2005 Form 433-A.
On September 1, 2005, the offer-in-compromise specialist
(second offer specialist) with the IRS offer-in-compromise unit
assigned to investigate petitioner’s June 24, 2005 offer-in-
compromise and petitioner’s June 24, 2005 Form 433-A made the
following pertinent entries in the “integrated collection system
history transcript”:
Initial Review: TP is making a DPO of $139,777 at
$1,664 in 84 payments to compromise approx $264,457
sole liability, on the basis of DATC.
* * * * * * *
- Special Circumstances: doubt as to collectibility,
because TP is 70-yr-old and his law practice is declin-
ing.
- Funding for the offer: Liquidation of assets and
borrowing.
* * * * * * *
TP is unmarried 70-yr old practicing attorney,
with no health issues and a household of 2 (18-yr old
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Last modified: March 27, 2008