added tax year 1992.
The IRS issued a letter formally rejecting Debtor's offer in compromise for tax years 1987 through 1992, as amended, on December 2, 1993. In addition, the IRS stamped each of Debtor's IRS Form 656 offers in compromise, which were acknowledged respectively on April 30, 1992, July 14, 1992 and April 6, 1993, "Rejected December 2, 1993."
Subsequently, on March 30, 1994, Debtor submitted a second offer in compromise on IRS Form 656 for tax years 1987 through 1993. The IRS acknowledged the offer on April 20, 1994. That offer was the first offer in compromise acknowledged by the IRS after assessment of Debtor's 1991 tax liabilities. Approximately seven hundred (700) days elapsed between the IRS's tax assessment of Debtor's 1991 tax liabilities and the April 20,1994 acknowledgment of Debtor's offer in compromise.
1992 Tax Year
The IRS assessed Debtor's liabilities for tax year 1992 on May 10, 1993. Debtor's first offer in compromise for tax year 1992 made after the assessment was the one acknowledged by the IRS on April 20, 1994. Three hundred fifty-two (352) days elapsed between date of the IRS's assessment of Debtor's 1992 tax liabilities and the April 20, 1994 acknowledgment of Debtor's offer in compromise, which included compromise of Debtor's 1992 tax liabilities. The IRS formally rejected Debtor's April 20, 1994 offer on August 19, 1994.
1993 Tax Year
The IRS assessed Debtor's 1993 taxes on May 30, 1994. On September 9, 1994, subsequent to the IRS's assessment of Debtor's 1993 tax liabilities. Debtor submitted an offer in compromise on IRS Form