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On June 21, 2004, Troy Talbott, the Appeals officer handling
the case, sent Wells a letter stating that he had started the CDP
review and that Wells had until July 8--just twelve business
days--to file Industrial’s overdue tax returns for 1996 and 2001
as well as submit any collection alternatives and current
financial statements. Two days later, Wells wrote back to
Talbott with a summary of a phone conversation they had earlier
that day, and promised to respond to Talbott’s request for
documents once he received an account history for Industrial. He
added that he would need an extension of the July 8 due date, but
did attach copies of Industrial’s 1996 and 2001 tax returns
(which had apparently already been filed) to his letter.
Talbott, it turned out, had anticipated Wells’s request for
an account history and mailed a copy to Industrial even before
Wells asked for one. Wells sent Talbott a brief note
acknowledging receipt of that history on June 28:
1. Receipt acknowledged. 2. It appears that 1990-1993
is the problem as no deductions. 3. The $1 million
income in 1990 never happened. 4. I will be sending
you some papers shortly.
Talbott understood this note to be an omen that Wells planned to
revisit the amount of tax owed, and replied with a letter dated
July 1, telling Wells that Industrial could not reargue the
underlying liability--it had already brought and settled a Tax
Court case for those years. His letter also reconfirmed the July
8 deadline to provide any documentation. With Independence Day
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Last modified: November 10, 2007