- 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