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offer-in-compromise. When the Appeals officer determined that
petitioner was not eligible for an offer-in-compromise, the
possibility of petitioner’s paying his tax liability through an
installment agreement was discussed.
The Appeals officer and petitioner negotiated a proposed
installment agreement under which petitioner was to make biweekly
payments of $370 until the unpaid tax liability was paid in full.
Entering into this agreement was conditioned upon petitioner’s
timely filing of a 2003 tax return. Petitioner also signed a
Form 2159, Payroll Deduction Agreement, which permitted
respondent to withdraw automatically biweekly payments from
petitioner’s wage payments beginning on May 21, 2004.
Between March 22 and April 15, 2004, the Appeals officer
contacted petitioner several times to notify him of his need to
file his 2003 tax return to be eligible for the installment
agreement. However, petitioner did not file his 2003 tax return
by April 15, 2004. On July 13, 2004, respondent issued a Notice
of Determination proposing a levy on petitioner’s assets.
On August 11, 2004, petitioner timely filed his petition
with this Court, challenging the amount assessed and requesting
an installment agreement. On April 28, 2005, respondent filed
the motion for summary judgment. Petitioner did not respond to
the motion.
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Last modified: May 25, 2011