- 4 - 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 neverPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011