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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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Last modified: May 25, 2011