- 50 - 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...)Page: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 NextLast modified: March 27, 2008