- 10 - uncovered.” The Appeals case memorandum concluded: “Hazards to the governments’ [sic] position appear to exist and there appears to be some grounds for settlement * * * Any percentage based settlement is clearly beyond the reach of the taxpayer based on the total balance of tax due and his relative inability to pay.” On May 9, 2002, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding his 1986, 1987, 1988, 1989, and 1992 tax years (notice of determination). In the notice of determination, respondent determined that the liens filed on or about April 9, 2001,6 were appropriate and “will remain in full force and effect until satisfied or unenforceable by law.” In discussing the OIC as a collection alternative, the attachment to the notice of determination (the attachment) noted: “While it appears clear that the taxpayer does not have the ability to liquidate the full amount of $7,000,000 a reasonable amount could not be calculated” and “additional investigation is required to determine an acceptable offer amount.” The attachment further noted that the OIC was returned to the compliance function for additional research and calculation. The attachment also stated that petitioner disputed the $5 million figure listed on the 1989 return, respondent had previously coded 6 It is unclear why the date was listed as Apr. 9, 2001, instead of Apr. 17, 2001.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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