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“an installment agreement cannot be entered into at this
time” because “the taxpayer is not in deposit compliance”.
The attachment dismisses petitioner’s concern about getting
a job on the ground that no wage levy would take place
until after he was employed, and once employed an employer
could not legally terminate him solely because a wage levy
was issued.
The attachment to the determination states that
petitioner “does not yet meet the compliance criteria for
an Installment Agreement or an offer [in compromise]”
because “Information on the Integrated Data Retrieval
System (IDRS) indicates the taxpayer has not filed an
income tax return for the period ending 12/31/2001 or
12/31/2002.” The attachment further states: “Although
the taxpayer’s average income for these periods is below
the filing requirement, he has made mortgage interest
payments during these years that would suggest that he is
also receiving self-employment income of some type.” Thus,
the Appeals officer appears to speculate that petitioner
received self-employment income during each of the years
2001 and 2002 in an amount sufficient to require that he
file a return. The Appeals officer concludes: “since the
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Last modified: May 25, 2011