context: What matters, however, is the probative value of such offers. This entails an analysis of the timing and circumstances under which they were made.
citation_a.signal: see also
citation_a.parenthetical: excluding as not probative offer made six years after tax delinquencies arose and just prior to defendant taking bench as a judge
citation_a.sentence: See United States v. Stoehr, 196 F.2d 276, 283 (3d Cir.1952) (finding that offer in compromise filed long after taxpayer learned of tax liability and without his having made any payment on the amount owed “destroyed whatever probative value a prompt offer might have had.”); see also United States v. McGill, 1991 WL 12346 *5 (E.D.Pa.) aff'd in part, rev’d in part 964 F.2d 222 (3d Cir.1992) (excluding as not probative offer made six years after tax delinquencies arose and just prior to defendant taking bench as a judge); see also Bateman v. United States, 212 F.2d 61, 68 (9th Cir.1954) (excluding evidence of tax protests as not probative on question of good faith where government had already commenced its investigation and audit of taxpayer); and see Hayes v. United States, 227 F.2d 540, 543 (10th Cir.1955) (excluding evidence of offer in compromise made 2% years after government brought fraud to tax payer’s attention)
citation_b.signal: see
citation_b.identifier: 196 F.2d 276, 283
citation_b.parenthetical: finding that offer in compromise filed long after taxpayer learned of tax liability and without his having made any payment on the amount owed "destroyed whatever probative value a prompt offer might have had."
citation_b.sentence: See United States v. Stoehr, 196 F.2d 276, 283 (3d Cir.1952) (finding that offer in compromise filed long after taxpayer learned of tax liability and without his having made any payment on the amount owed “destroyed whatever probative value a prompt offer might have had.”); see also United States v. McGill, 1991 WL 12346 *5 (E.D.Pa.) aff'd in part, rev’d in part 964 F.2d 222 (3d Cir.1992) (excluding as not probative offer made six years after tax delinquencies arose and just prior to defendant taking bench as a judge); see also Bateman v. United States, 212 F.2d 61, 68 (9th Cir.1954) (excluding evidence of tax protests as not probative on question of good faith where government had already commenced its investigation and audit of taxpayer); and see Hayes v. United States, 227 F.2d 540, 543 (10th Cir.1955) (excluding evidence of offer in compromise made 2% years after government brought fraud to tax payer’s attention)