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As noted above, on or about October 21, 2003, a Notice
of Federal Tax Lien was filed with respect to petitioner’s
outstanding tax liabilities (the NFTL). By letter dated
October 27, 2003, petitioner was advised of the event and
notified of his right to request an administrative hearing to
dispute it, which he did in a request dated November 27, 2003.
A short time earlier, by letter dated November 19, 2003,
petitioner was advised that the 2003 offer had been rejected
because: (1) It was “less than * * * [petitioner’s] reasonable
collection potential”; and (2) petitioner had “failed to provide
the requested information and documentation” about his wife’s
income and expenses. That letter also advised petitioner that he
could appeal the rejection of the 2003 offer, which he did by
letter dated December 18, 2003.
Petitioner’s request for an administrative hearing with
respect to the NFTL and his appeal of the rejection of the 2003
offer were assigned to Settlement Officer Michael Blais (Mr.
Blais). For reasons discussed in a memorandum dated December 15,
2004, Mr. Blais upheld the rejection of the 2003 offer.
During the administrative hearing conducted in connection
with the NFTL, petitioner offered an installment agreement as an
alternative collection action. Under the terms of the proposed
installment agreement, petitioner offered to pay $100 per month
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Last modified: November 10, 2007