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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”.
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Last modified: May 25, 2011