Henry M. Lloyd - Page 49




                                       - 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  Next 

Last modified: March 27, 2008