Susan P. Obersteller - Page 3




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               Between January 24 and May 7, 2001, petitioner, petitioner's           
          spouse, and petitioner’s legal representative exchanged a number            
          of letters with respondent’s Appeals officer in which petitioner            
          explained that petitioner would only be satisfied if respondent             
          provided to petitioner not the above transcripts of account but             
          specifically “Forms 23C, Summary Record of Assessments” relating            
          to petitioner’s Federal income taxes for 1992 and 1993.                     
               In his letters, respondent’s Appeals officer made it clear             
          that respondent was relying on the above referenced transcripts             
          of account, not “Forms 23C”, to verify the assessments that were            
          the bases for the lien filing, and that respondent was willing to           
          meet face-to-face with petitioner and petitioner’s spouse and               
          representative and to make available to petitioner additional               
          copies of those transcripts.  Respondent’s letters also suggested           
          specific dates for a face-to-face meeting, but petitioner and               
          petitioner’s representative refused to meet with respondent’s               
          Appeals officer unless a commitment was made by the Appeals                 
          officer to obtain and to have at the meeting a copy of                      
          “Forms 23C” relating to petitioner’s 1992 and 1993 Federal income           
          taxes.                                                                      
               On May 17, 2001, respondent’s Appeals Office mailed to                 
          petitioner’s representative a notice of determination in which it           
          was explained that the above lien filing made by respondent with            








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