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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:
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