Brown v. Commissioner, 158 T.C. No. 9| June 23, 2022 | Lauber, J.| Dkt. No. 11519-20L
Summary: Michael Brown had tax liability exceeding $50 million. This case regards that liability, collection due process (CDP), and review of a determination by the IRS to reject an offer-in-compromise (OIC). On November 9, 2017, the IRS issued petitioner Notice of Federal Tax Lien Filing (NFTL). Brown timely requested a CDP hearing and checked the box “Offer in Compromise.” On April 19, 2018—and while Brown litigated other OIC and CDP issues through the Tax Court and the Ninth Circuit Court of Appeals—he submitted Form 656, Offer in Compromise, in which he offered to pay $320,000 in satisfaction of his liabilities for all years. The settlement officer (SO) referred the OIC to the IRS’s Centralized Offer in Compromise Unit (COIC unit). In May 2018, the COIC unit determined that the offer met the IRS formal requirements. The offer was then referred to a collection specialist (CS). On November 5, 2018, the CS issued Brown a letter informing him that the IRS had “closed [the] file” and was “returning your Form 656, Offer in Compromise” because “[o]ther investigations are pending that may affect the liability sought to be compromised or the grounds upon which it was submitted.”
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