Claude E. and Dana L. Salazar - Page 7




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          bankruptcy file and noting that “secured claims get paid first              
          and then priority.”  Mr. Conte noted in his case record that                
          there were also outstanding employment tax liabilities for                  
          petitioners and that final collection notices had not yet been              
          issued with respect to those liabilities.                                   
               On or about May 24, 2004, petitioners submitted a completed            
          Form 656, Offer in Compromise, to respondent seeking to resolve             
          their outstanding employment and income tax liabilities for                 
          $9,024.25, to be paid within 90 days from notice of acceptance of           
          the offer.  Upon receipt of the offer-in-compromise, Mr. Conte              
          contacted petitioners to seek additional financial information.             
          Over the course of several months, Mr. Conte and petitioners                
          corresponded on multiple occasions with respect to additional               
          documents Mr. Conte needed in evaluating petitioners’ offer-in-             
          compromise.  In one letter to Mr. Conte dated August 13, 2004,              
          petitioners requested that “given that the Bankruptcy Court has             
          failed to render a final accounting to date, the penalties                  
          attributable to the principal balance outstanding should be                 
          waived.”                                                                    
          While he was attempting to obtain additional information                    
          about petitioners’ economic situation, Mr. Conte was also                   
          attempting to determine what amount would be paid to respondent             
          from petitioners’ bankruptcy estate.  Mr. Conte contacted                   
          respondent’s internal bankruptcy specialists on numerous                    







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