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On April 19, 2000, Rosado wrote to Stone. His letter noted
that he and Stone had discussed a monthly payment plan for
petitioner’s 1993 income tax liability and asked for copies of a
number of documents relating to petitioner’s financial status.
The letter further indicated that Rosado had enclosed transcripts
of petitioner’s income tax accounts for 1993, 1995, and 1997, as
well as IRS publications relating to preparation of financial
statements, to the IRS collection process, and to "Your Rights as
a Taxpayer". The letter concluded as follows:
5. Notice of Federal Tax Lien. Per our conversation,
I will delay Filing Notice of Federal Tax Lien
until May 15, 2000. At that time I will re-
evaluate the need for filing. We had discussed
alternatives to filing a Notice of Lien such as
the posting of a bond. I would expect your
proposal on this matter no later than 5/15/2000.
6. You had indicated that notice of assessment for
1995 and 1997 was not received. Is this correct?
7. For your information I have requested the
administrative case file for 1995 and 1997, so
that any issues can be addressed. As soon as I
receive these files, I will share it with you. I
also agreed to delay filing Notice of Federal Tax
Lien for these periods until we can address the
assessments. If there are no unresolved issues
regarding assessments, then collection of the
balance due will be addressed. Will also address
filing of Notice of Federal Tax Lien.
8. During the interim, please advise Mr. Hyler that
he can begin sending payments of $5000 to my
office. Please note that penalties and interest
continue to accrue on any unpaid balance. This is
not an acceptance of a monthly payment proposal.
That will be determined at a later time.
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