James J. Crisan and Veronica L. Crisan - Page 4

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          an attorney and attached Mr. Crisan’s Form W-2, Wage and Tax                
          Statement, for 2001, which reported $119,120 of wages, tips, and            
          other compensation.                                                         
               During a telephone conversation on April 29, 2002, the                 
          Appeals officer requested again that petitioners provide an offer           
          of a monthly installment amount to pay off the tax liabilities.             
          On May 13, 2002, Mr. Crisan sent the Appeals officer a letter               
          requesting a 2-week extension of time, stating that he was unable           
          to commit to a monthly payment amount because he wanted to review           
          his pension plan policies.  Other than the proposed installment             
          payment amount of $100 per month, petitioners never made a formal           
          offer of an installment agreement and sent no further information           
          or correspondence to respondent.                                            
               On June 12, 2002, respondent sent petitioners a notice of              
          determination for the years in issue.  Respondent sustained the             
          levy action, stating:                                                       
                    We have determined that no relief is to be granted in             
               this case.  You have requested that the liability at issue             
               be resolved via an offer in compromise.  However, your                 
               financial data indicate that you can satisfy the liability             
               by liquidating assets or with an installment agreement.                
               Your request for additional time to consider your options is           
               unrealistic and is denied.  Appeals believes that the need             
               for efficient collection of taxes has been balanced with               
               your concern for the intrusiveness of the proposed                     
               assessment.                                                            
          Further, respondent explained:                                              
                    An offer in compromise, doubt as to collectibility is             
               not appropriate as the taxpayers have the assets to                    
               immediately full [sic] pay the tax liability.  In addition,            





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