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That same day, the Appeals officer made inquiries of other IRS
personnel about a possible stock sale and was advised that “if
FMV [fair market value] is determinate we can sell, but if FMV is
not determinate, then per IRM [Internal Revenue Manual] we have
to sell at auction”.
In an entry in her case activity records dated September 12,
2001 (1 day after the terrorist attacks of September 11, 2001),
the Appeals officer indicated that she would “continue to
research/work with rep on possible sale of stock he has requested
to happen”.
A September 13, 2001, entry in the Appeals officer’s case
activity records states: “rep called-wants to sell stock-I
previously talked to RO-he has no problems with it-have to
determine FMV-rep to submit info to me in writing-and to RO who
will verify and let me know.” An entry dated October 11, 2001,
states: “Need to call rep-re status of Appeal * * * funds have
been levied under jeopardy levy-tp wanted to sell them while they
still had value-RO does not object-will oversee-then 9-11 attack-
market fell-therefore, believe sale of stock has not happened.”
An entry dated January 22, 2002, repeats this language verbatim.
Finally, an entry dated February 12, 2002, indicates that the
Appeals officer called Revenue Agent F. Stevens who “stated he
did not know status of case, and that rep did not provide stock
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Last modified: May 25, 2011