- 4 - hearing).2 At the July 6, 2000, hearing, the issues raised by Mr. Toscher were the possibility of full payment of petitioner’s 1991 and 1992 income tax liabilities, the renegotiation and revision of the 1998 installment agreement, and the possibility of an offer-in-compromise. Mr. Toscher had no information regarding petitioner’s financial status to provide to Appeals Officer Bailey. Appeals Officer Bailey agreed to meet with Mr. Toscher again on November 9, 2000, to give petitioner the opportunity to present his financial information to respondent. Before November 9, 2000, Appeals Officer Bailey filled out a “CDP Priority Case Action Plan”. He completed this form because the case was over 180 days old and the total tax liability was over $500,000. In the section entitled “Action plan”, Appeals Officer Bailey wrote: This taxpayer owes a lot of money and has many assets, the representative now realizes that the taxpayer may if [sic] fact have to full pay these deficiencies. I have a 2nd hearing scheduled for 11/9/2000, at which time the representative should have a full accounting of the taxpayer’s assets and ability to pay. On that date either arrangement for full payment will be made or the taxpayer’s representative will present an offer- in-compromise. Case delayed due to open related cases in appeals. Representative wanted those concluded first. On November 9, 2000, Appeals Officer Bailey and Mr. Toscher met regarding petitioner’s case (November 9, 2000, meeting). Mr. 2 Appeals Officer Bailey was not involved in the approval of, or the notification of default on, the 1998 installment agreement.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011