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According to respondent’s motion, during the telephone
conversation on August 18, 2003, “petitioner said he was not
sure he wanted an installment agreement and [petitioner]
would call the Appeals officer on August 19, 2003 if
interested”. The motion states that “Petitioner did not
pursue this matter further.”
Respondent’s motion is supported by the Declaration of
the Appeals officer. Among the documents attached to the
Declaration, is the “Case Activity Records”, which purports
to show all of the actions taken by the Appeals officer
regarding the case. That document refers to a conference
on June 17, 2003, and another contact with petitioner on
July 22, 2003 (“Requested additional info and TP wants an
IA”). These items are not discussed in the Declaration or
in respondent’s motion.
In any event, on August 29, 2003, the Commissioner
issued Notice of Determination Concerning Collection
Action(s) under Section 6320 and/or 6330 (referred to herein
as notice of determination), which contemplates permitting
the collection action to proceed. The notice of
determination states as follows:
Summary of Determination
Although you wanted an installment agreement, you
were not in compliance. In addition you never
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Last modified: May 25, 2011