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that petitioner owed approximately $222 for the tax year 2004.
The proposed installment agreement provided that petitioner would
pay $50 each month beginning January 21, 2006.
Petitioner did not believe that he owed the amount indicated
for 2004. On the contrary, he believed that he was entitled to a
refund, and therefore he refused to sign the installment
agreement. Petitioner explained his reluctance to sign the
proposed installment agreement in a voice mail message to
respondent’s Appeals officer on January 17, 2006. Petitioner
reiterated his position in a telephone conversation with the same
Appeals officer on January 19, 2006, and again in a letter to the
same Appeals Officer dated January 20, 2006, and received by the
Appeals officer on February 3, 2006. In the January 20 letter,
petitioner wrote that he was, however, “happily cooperating with
the IRS by making voluntary payments until this 2004 tax issue
can be resolved.” Respondent’s records show that petitioner made
five payments of $50 each between January and April of 2006.1
On February 10, 2006, respondent’s Appeals officer sustained
the proposed levy action. The Appeals officer’s notes indicate
that in communicating to petitioner his intention to sustain the
proposed levy action, the Appeals officer advised petitioner that
he did not have jurisdiction over tax year 2004 and that
1Petitioner had also made a $50 payment in July of 2005.
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