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petitioners’ file. Watson called Washburn, and he found
petitioners’ file on November 7, 2001.
Petitioner called Watson on November 7, 2001, to ask her to
give him a statement that respondent was trying to resolve his
case.
Washburn delivered the file to Watson on November 8, 2001.
On that day, Watson called respondent’s examination division and
asked for an expedited audit of petitioners’ returns when she
received them. Watson did not work on petitioners’ case during
unspecified dates between November 9, 2001, and January 17, 2002,
because she was busy working on cases calendared for trial that
month and because she took annual leave that she would otherwise
have lost. Watson received petitioners’ original and amended
returns from an employee of respondent on December 5, 2001.
Watson resumed working on petitioners’ case on January 17,
2002. On January 24, 2002, using some of the checks petitioner
had provided, Watson showed him that the amounts that petitioners
had reported on their original returns for telecommunications
expenses were correct. Petitioner agreed that Watson was
correct.
Watson told petitioner that petitioners must pay taxes they
owed to remove the lien. On January 24, 2002, petitioner told
Watson that petitioners wanted to file an offer in compromise
because they did not have enough money to pay the tax and
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