- 4 - Steven R. Mather (Mr. Mather), requested respondent’s revenue officer to liquidate the stock accounts and apply the proceeds to petitioners’ outstanding tax liabilities. The revenue officer directed Mr. Mather to get the Appeals officer’s approval for the stock sale. Consequently, on August 23, 2001, Mr. Mather faxed to the Appeals officer a request for her approval of the stock sale. The fax (which is not in evidence) is described in the Appeals officer’s contemporaneous case activity records as “asking me for a letter to say okay to release stock for sale”. On September 7, 2001, the Appeals officer called Mr. Mather about this request. An entry in the Appeals officer’s case activity records dated September 7, 2001, states: Called rep [Mr. Mather]-re sale of stock that had been levied under jeopardy assessment although no move had been made to sell stock because of CDP hearing. Per rep-tp [taxpayer] wants to sell stock while it still has value and have proceeds appkied [sic] to tax. Told rep that I would like him to put his request in writing and send to me w/cc to RO [revenue officer] since he is still working with the RO. He said he will do. Informed rep that I was going to talk to RO about stock sale-he was okay with me doing that-rep had already talked to him about too [sic]. That same day, the Appeals officer called the revenue officer, who indicated that petitioners had “a lot” of shares of stock that were not widely traded and that he wanted to determine the fair market value and have all proceeds applied to petitioners’ deficiency. The Appeals officer’s contemporaneous case activity records state that this “is what I also want”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011