- 49 - specialist’s September 6, 2004 letter, the first offer specialist informed petitioner that his offer-in-compromise had to be perfected to reflect Federal excise tax assessed for the tax periods ended December 31, 1991, and December 31, 1992. In the first offer specialist’s September 15, 2004 letter, the first offer specialist informed petitioner (1) that an offer-in- compromise may be returned where there is insufficient Federal income tax withheld or paid and (2) that respondent’s records indicated that insufficient Federal income tax had been withheld with respect to petitioner’s taxable year 2003. The first offer specialist and Mr. Silverberg had a tele- phonic discussion on September 17, 2004. On October 1, 2004, the first offer specialist left a voice mail for Mr. Silverberg. Thereafter, Mr. Silverberg sent Mr. Silverberg’s October 1, 2004 letter to the first offer specialist and enclosed with that 28(...continued) If an offer accepted for processing does not contain sufficient information to permit the IRS to evaluate whether the offer should be accepted, the IRS will request that the taxpayer provide the needed additional information. If the taxpayer does not submit the additional information that the IRS has requested within a reasonable time period after such a request, the IRS may return the offer to the taxpayer. The IRS may also return an offer to compromise a tax liability if it determines that the offer was submitted solely to delay collection or was otherwise nonprocessable. An offer returned following acceptance for processing is deemed pending only for the period between the date the offer is accepted for processing and the date the IRS returns the offer to the taxpayer. * * *Page: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 NextLast modified: March 27, 2008