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the issuance of this letter, AO Petrohovich corresponded with
Appeals Chief Gretes regarding the contents of the June 16, 1999,
memorandum written by RC Stanley.
On September 1, 2000, Appeals Chief Gretes agreed to the
rejection of the Offer in Compromise.
On September 5, 2000, AO Petrohovich sent a letter to
petitioners, with a copy to Mr. Crowgey, rejecting the Offer in
Compromise. The parties stipulated that petitioners did not
appeal this determination directly to this Court, or to any other
court, since no such appeal was allowed for the IRS’s rejection
of their Offer in Compromise.
On December 25, 2000, the IRS issued to petitioners a “Final
Notice - Notice of Intent to Levy” (Notice of Intent to Levy)
with regard to income tax liabilities for tax years 1991, 1992,
1993, and 1999.
On January 23, 2001, petitioners requested a hearing
pursuant to section 6330 with respect to the Notice of Intent to
Levy.
On January 25, 2001, Mr. Crowgey sent a letter to Appeals
Chief Gretes, with a copy to Daniel Black, National Chief,
Appeals, requesting that “his entire office recuse itself from
this case at this time and this case file either be referred to
another regional office or to the national office in Washington,
D.C.”
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