Ex. I

Rejection Letter

Letter to the Proponent

Dear Mr./Mrs./Miss/Ms. [Name]:

This refers to your offer dated ___________________________, submitted on behalf of _________________________________________ to settle the [above-entitled case(s)] [Internal Revenue Service's claim asserted in the above-entitled case(s) [against _____________________________ for [______________________________ (tax(es)] [Section 6672 penalty with respect to (name of corporation) ___________________________________________] for the period ____________________________________] [against (describe the particular fund or property which is the subject of the settlement ___________________________________________________].]

After careful consideration, this offer has been rejected on behalf of the Attorney General.

    Sincerely yours,

[NAME OF ASSISTANT ATTORNEY GENERAL]
Assistant Attorney General
Tax Division

By:

[NAME OF CHIEF OF SECTION]
Chief, ___________ Section

cc: United States Attorney
     [District] [Chief] Counsel

[May 1995]

Rejection Letter

Letter to [District] [Chief] Counsel

Dear Mr./Mrs./Miss/Ms. [Name]:

There is enclosed a copy of our letter of this date

advising the proponent of the rejection of the offer to compromise the [above-entitled case(s)] [Internal Revenue Service's claim asserted in the above-entitled case(s) [against ___________________________ for [_____________________________ (tax(es)] [Section 6672 penalty with respect to (name of corporation) ______________________________________________] for the period ________________________________________] [against (describe the particular fund or property which is the subject
of the settlement ___________________________________________].]

In taking this action the Department carefully considered the views expressed in your letter of __________________________. The offer was rejected, however, for the reasons set forth in the enclosed memorandum of _____________________________.

    Sincerely yours,

[NAME OF ASSISTANT ATTORNEY GENERAL]
Assistant Attorney General
Tax Division

By:

[NAME OF CHIEF OF SECTION]
Chief, ___________ Section

Enclosures

(For use only when rejection is contrary to Internal Revenue Service recommendation.)

[May 1995]

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Section IV || Section V || Section VI || Appendices
Table of Cases and Authorities