Christopher Michael Frazier - Page 3

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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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