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hearing).2 At the July 6, 2000, hearing, the issues raised by
Mr. Toscher were the possibility of full payment of petitioner’s
1991 and 1992 income tax liabilities, the renegotiation and
revision of the 1998 installment agreement, and the possibility
of an offer-in-compromise. Mr. Toscher had no information
regarding petitioner’s financial status to provide to Appeals
Officer Bailey. Appeals Officer Bailey agreed to meet with Mr.
Toscher again on November 9, 2000, to give petitioner the
opportunity to present his financial information to respondent.
Before November 9, 2000, Appeals Officer Bailey filled out a
“CDP Priority Case Action Plan”. He completed this form because
the case was over 180 days old and the total tax liability was
over $500,000. In the section entitled “Action plan”, Appeals
Officer Bailey wrote:
This taxpayer owes a lot of money and has many assets,
the representative now realizes that the taxpayer may
if [sic] fact have to full pay these deficiencies. I
have a 2nd hearing scheduled for 11/9/2000, at which
time the representative should have a full accounting
of the taxpayer’s assets and ability to pay. On that
date either arrangement for full payment will be made
or the taxpayer’s representative will present an offer-
in-compromise. Case delayed due to open related cases
in appeals. Representative wanted those concluded
first.
On November 9, 2000, Appeals Officer Bailey and Mr. Toscher
met regarding petitioner’s case (November 9, 2000, meeting). Mr.
2 Appeals Officer Bailey was not involved in the approval
of, or the notification of default on, the 1998 installment
agreement.
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