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letter petitioner’s September 29, 2004 offer-in-compromise.29
That offer-in-compromise did not offer to compromise the Federal
excise tax with respect to the tax periods ended December 31,
1991, and December 31, 1992, to which the first offer specialist
referred in the first offer specialist’s September 6, 2004
letter.30 On November 3, 2004, respondent’s collection division
sent a letter to petitioner in which respondent stated: “Our
records indicate the following period(s) was/were not included:
Excise tax for 1991 and 1992 tax periods.”31 On the record
29The record does not indicate whether Mr. Silverberg re-
sponded in Mr. Silverberg’s October 1, 2004 letter to all of the
requests that the first offer specialist made to Mr. Silverberg.
30In contrast, petitioner’s June 24, 2005 offer-in-
compromise offered to compromise not only petitioner’s unpaid
liabilities for 1990, 1991, 1992, 1994, 1996, 1997, and 2002 but
also the Federal excise tax for the tax periods ended Dec. 31,
1991, and Dec. 31, 1992.
31Respondent’s November 3, 2004 letter further stated:
We are returning your Form 656, Offer in Compro-
mise for the following reasons(s):
All tax periods with a balance due must be in-
cluded in your Offer in Compromise. Our records indi-
cate the following period(s) was/were not included:
Excise tax for 1991 and 1992 tax periods.
If a deposit was made with the offer, we will mail
the refund separately in four to six weeks.
If you believe the return of your offer was made
in error, or your failure to provide the information/
substantiation we requested was due to circumstances
beyond your control (your serious illness, death or
serious illness of your immediate family member, or
(continued...)
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Last modified: March 27, 2008