- 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 agreement. 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 follows: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