- 4 - record of actions that he took with respect to the request that he considered to be significant, including correspondence and other contacts with petitioner and the final disposition of the request (the case activity record). The entry in the case activity record for October 12, 2001, chronicles a telephone conversation with petitioner. In pertinent part, it states: “Personal conference is not necessary per [petitioner]. Telephone discussion will be fine.” The remainder of the entry discusses (1) an offer in compromise that petitioner claimed to have filed, but as to which Mr. McNichol could find no evidence in an Internal Revenue Service (IRS) database, and (2) Mr. McNichol’s advice to petitioner that, before an offer in compromise could be considered, she must file her 2000 return. Mr. McNichol’s entry in the case activity record for December 4, 2001, states that petitioner filed her 2000 return and that the IRS received an offer in compromise from petitioner. The entry states that there were problems with the offer and that Mr. McNichol sent a letter to petitioner asking for revisions to the offer and for additional information; the entry further states that petitioner would be allowed 30 days to respond. An entry for January 2, 2002, states that there had been no word from petitioner and that Mr. McNichol had determined to sustain the collection (levy) action. A further entry for that date states that Mr. McNichol had prepared the case for closing.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011