- 5 - Toscher still had no information regarding petitioner’s financial status to provide to Appeals Officer Bailey. On November 13, 2000, Mr. Toscher wrote to Appeals Officer Bailey. The letter thanked Appeals Officer Bailey for meeting with him, stated that Mr. Toscher understood that Appeals Officer Bailey could no longer hold on to the case and needed to issue a determination, and thanked Appeals Officer Bailey for his consideration of this matter. Appeals Officer Bailey prepared an “Appeals Case Memo”. In it, he wrote: The taxpayer has many holdings, both real estate and businesses. * * * although the taxpayer’s corporate businesses may be legally titled to the taxpayer’s wife, these corporations owe the taxpayer sizable amounts of money * * * . It appears now that the taxpayer may be able to full pay all of the outstanding taxes * * * . At Appeals last meeting with the taxpayer’s representative on the CDP matter, such an accounting was still in the process of being made and the representative could not give Appeals a reasonable date for the conclusion of such accounting. On December 5, 2000, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding his 1991 and 1992 tax years (notice of determination). In the notice of determination, respondent determined that the proposed levy was appropriate. The notice of determination explained: Along with your Form 12153, Request for a Collections Due Process Hearing, you offered no alternative to enforced collection, but suggested that your defaulted installment agreement might be renegotiated andPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011