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your client’s offer be rejected without further consideration.”
On February 18, 2003, Mr. Karaszkiewicz hand-delivered documents
to Mr. Kroll in response to the January 21, 2003, letter.
In his examination of the hand-delivered documents,
Mr. Kroll found that several of the requested items had not been
provided. He further became privy to new facts indicating that
additional collection information statements would be required in
order to complete consideration of the offer. Specifically, the
documents revealed that petitioner owned yet another corporation
and had recently married, necessitating collection information
with respect to the company and to petitioner’s spouse.
Mr. Kroll advised Mr. Karaszkiewicz of these developments by
telephone on March 10, 2003, and Mr. Karaszkiewicz said he would
try to provide the requested materials by March 25, 2003.
On March 26, 2003, Mr. Karaszkiewicz sent to Mr. Kroll a
brief fax stating as follows: “Mr. Kroll, please excuse the
delay in providing the additional documentation which we
discussed. This delay has been caused exclusively by my trial
commitments. I have not been able to review the documents with
Mr. Roman. I assure you that we will quickly provide them.”
When, 6 weeks later, the requested information had not been
submitted, Mr. Kroll determined that the proposed collection
alternative could not be accepted and that collection by levy
should proceed. The corresponding Notice of Determination
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Last modified: May 25, 2011