Antonio L. and Ernestine Thomas - Page 5

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          Petitioner Antonio Thomas telephoned the settlement officer on              
          November 14, 2001, to postpone this meeting because his                     
          representative was ill, and the scheduled meeting did not take              
          place.  A second meeting was scheduled for December 3, 2001, at             
          10 a.m.  Petitioners failed to appear, and in the afternoon of              
          that day, a representative of petitioners contacted the                     
          settlement officer to request a further postponement.  The                  
          representative was advised that Appeals would close the case and            
          issue a determination.                                                      
               On December 12, 2001, respondent issued a Notice of                    
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (determination letter).  Therein, the settlement                
          officer first determined that all applicable laws and                       
          administrative procedures had been met for all liabilities at               
          issue except for the 1985 taxable year; for 1985, the settlement            
          officer determined that petitioners’ liability had been                     
          discharged in the bankruptcy proceeding.  With respect to issues            
          raised by petitioners, the determination letter concluded that              
          all of the issues raised by petitioners related to the validity             
          of the assessments and that all of the assessments except for the           
          one relating to 1985 were valid.  Finally, the determination                
          letter concluded that the proposed collection action                        
          appropriately balanced petitioners’ interests with the need for             
          efficient tax collection, noting a “pattern of unresponsiveness”            






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