- 4 - The parties’ disagreement whether the period of limitations governing collection for the taxable years 1982 and 1985 remained open in May 1998 turns on the specific date in 1990 that petitioner and her husband submitted the offer-in-compromise in question. Relying on entries appearing in transcripts of petitioner’s accounts, specifically Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, for the taxable years 1982 and 1985, and a Master File Transcript (TAXMODA) for the taxable year 1985, respondent determined that the offer-in-compromise was submitted on January 4, 1990, making the 1998 levy timely. Relying primarily on correspondence from the revenue officer tasked with reviewing petitioner’s offer-in- compromise, petitioner asserted that the offer was submitted on November 29, 1990, in which case the 1998 levy was untimely. There is no dispute that petitioner withdrew the offer-in- compromise on June 28, 1991. In November 2000, petitioner requested the assistance of the Internal Revenue Service Taxpayer Advocate Service (TAS) with regard to her refund claims for the taxable years 1982 and 1985. By letter dated September 11, 2001, TAS informed petitioner that its review of the matter revealed that, as of May 1998--the date respondent collected funds from petitioner’s retirement account--Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008