Albert G. Cooper - Page 8

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          See Grant Creek Water Works, Ltd. v. Commissioner, 91 T.C. 322,             
          325 (1988); Casanova Co. v. Commissioner, 87 T.C. 214, 217                  
          (1986).                                                                     
               In the instant case, the Appeals officer’s January 23, 2002,           
          letter, responding to petitioner’s January 14, 2002, letter,                
          addressed the issue of an offer in compromise or collection                 
          alternatives.  Petitioner’s January 30, 2002, letter, sent in               
          reply to the Appeals officer’s January 23, 2002, letter, stated             
          that petitioner’s counsel was attempting to contact petitioner in           
          an effort to discuss the issues proposed in respondent’s January            
          23, 2002, letter.  Petitioner’s January 30, 2002, letter                    
          indicated that an extension of time for reply to the Appeals                
          officer’s January 23, 2002, letter was necessary because                    
          petitioner, a truck driver, was unavailable to consider the                 
          Appeals officer’s letter.                                                   
               The attachment to the notice of determination refers to the            
          Appeals officer’s January 23, 2002, letter to petitioner and                
          indicates that the period for petitioner to respond to that                 
          letter was extended.  However, according to respondent, no                  
          communication from petitioner was received regarding that issue.            
               Petitioner contends that his counsel sent respondent a                 
          letter on March 4, 2002, in which petitioner sought to negotiate            
          an offer in compromise or a collection alternative with the                 
          Appeals officer.  Petitioner alleges that letter states:  “After            






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