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January 18, 2002, respectively, confirms that a telephone
conference between the two had taken place and that petitioner’s
opposition to collection of his outstanding liabilities for the
years in issue was based primarily upon the following facts
alleged by petitioner:
(1) On October 8, 1991, while residing in Los Angeles,
California, petitioner met with an employee of respondent’s Los
Angeles office (the IRS employee) for the purpose of negotiating
and executing an installment payment agreement as a means of
discharging his outstanding liabilities for several tax years,
including the years in issue.
(2) The IRS employee told petitioner that he would be
required to sign extensions of the period of limitations on
collection (Forms 900) in order to obtain an installment
agreement.
(3) Petitioner signed two extensions in blank; they were
filled in and signed later by an IRS employee, not in
petitioner’s presence. Copies of the completed extensions were
furnished to petitioner approximately 2 weeks after he signed
them.
(4) Respondent’s Los Angeles office did not afford
petitioner an opportunity to enter into an installment payment
agreement.
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