Katherine Ilovar Rodriguez - Page 10

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               Petitioner did not appear at the date and time Ms. Dellosso            
          had set for a meeting with petitioner, July 12, 2005, at 10 a.m.            
          About 2 hours after the time of the appointment, petitioner                 
          called Ms. Dellosso and stated that she was unable to make the              
          appointment.  Petitioner asked for an opportunity to speak to her           
          accountant and was given 2 days to do so.                                   
               Petitioner called Ms. Dellosso 2 days following the canceled           
          appointment, stated that she had been unable to contact her                 
          accountant, and requested an installment agreement only for 1993            
          through 1995.  According to the case records, Ms. Dellosso                  
          informed petitioner that although she could pay what she wanted,            
          all years had to be included in either an installment agreement             
          or an OIC.  Ms. Dellosso terminated the call after an unpleasant            
          exchange of words.                                                          
               The notice of determination was issued on July 27, 2005.               
          The Issue for the Court                                                     
               The underlying tax liabilities are not at issue in this                
          case.2  The issue for the Court to decide is whether respondent             
          abused his discretion in determining to pursue the intended                 
          collection action.                                                          




               2Petitioner conceded at trial the underlying tax liabilities           
          and with them the abatement of interest and penalties raised in             
          the petition.  See sec. 6201; supra note 1.  Had petitioner not             
          conceded the issues, she would be precluded from raising them.              
          See sec. 6330(c)(2)(B); sec. 301.6320-1(e)(3), Q&A-E2, Proced. &            
          Admin. Regs.                                                                



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