Joseph G. Dostal - Page 12

                                       - 12 -                                         
             another collection alternative.  In response, petitioner’s               
             attorney proposed that petitioner enter into an installment              
             agreement.  The Appeals officer responded that certain                   
             conditions must be met before she would consider an                      
             installment agreement.  These included “payment in full for              
             the amount determined to be owed for the tax year 2003,                  
             including the estimated tax penalty computed to be due”, a               
             substantial payment of petitioner’s tax liability for                    
             taxable years 2000 and 2001, and submission of copies of                 
             the Forms W-2, Wage and Tax Statement, for petitioner and                
             his wife for taxable year 2003.  Petitioner’s attorney                   
             notified the Appeals officer that petitioner could not meet              
             the specified conditions for entry into an installment                   
                  In due course, the Appeals officer issued her                       
             determination that “the Notice of Intent to Levy and the                 
             proposed collection action was appropriate.”  In an                      
             attachment to the notice of determination, the Appeals                   
             officer summarized her discussions with petitioner’s                     
             attorney, the most significant of which are summarized as                

Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011