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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. * * *
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Last modified: March 27, 2008