William G. Wells - Page 5

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            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 and                                       





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