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On or about March 21, 2005, petitioner’s authorized repre-
sentative sent the Appeals officer another letter (petitioner’s
March 21, 2005 letter). That letter stated in pertinent part:
We are writing on behalf of * * * [petitioner] regard-
ing the outstanding 1999 balance * * *.
We previously corresponded with you on this issue in a
letter dated December 30, 2004 in which we laid out
specific points for abatement of the penalties. We
also submitted additional information on the medical
problems suffered by the taxpayer on January 29, 2005
as requested. We are requesting a written response to
each of these points, since they have summarily been
rejected.
We are also asking for written response to our calcula-
tion of the amounts due, based on the calculations we
submitted along with the aforementioned correspondence
of December 30, 2004.
Further, we would like a written determination of the
amount due for 1999.
The taxpayer is not proposing an offer in compromise at
this time, and therefore is not submitting Form 433-A.
On or about March 25, 2005, in response to petitioner’s
March 21, 2005 letter, the Appeals officer sent petitioner’s
authorized representative a letter. That letter stated in
pertinent part:
In response to your latest correspondence and fax, I am
writing this letter.
You did submit arguments about the penalties for 1999
and submitted evidence of the taxpayer’s medical condi-
tion since 1999. There have been other arguments about
the computations of the balance due. I reviewed the
file and find insufficient evidence overcomes the
penalties. The computations of the balances due have
been found to be correct. I found one exception in
that a levy was taken during the period of collection
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Last modified: May 25, 2011