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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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Last modified: May 25, 2011