Richard M. Downing - Page 10

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          file memorandum addressed to “Greg”, Appeals Officer Dugan stated           
          that she was “trying to get rid of a really messy CDP [collection           
          due process case] as I don’t want anybody else to have to spend             
          time unraveling the mystery.”  In this file memorandum, Appeals             
          Officer Dugan recounted petitioner’s explanation that in August             
          1996 he had filed a 1995 married filing separate return that                
          showed a balance due, but that in October 1996, petitioner and              
          Astrid Downing had filed an amended return converting their prior           
          1995 returns to joint filing status and had paid the $8,728                 
          balance shown on this amended joint return.  Appeals Officer                
          Dugan’s file memo stated:  “I happen to believe the taxpayer.”              
          The file memo concluded:  “If I post the amended return along               
          with the payments the taxpayer made, there is no balance due on             
               In a letter dated November 23, 2004, and addressed to                  
          petitioner’s representative Harold Wolgast, Appeals Officer Dugan           
          reiterated her belief that petitioner and Astrid Downing had                
          filed a joint amended 1995 return.  She stated:  “I do not know             
          what the reason is for the return not being processed, but I will           
          request that it be input as of 10/30/1996.”                                 
               On December 9, 2004, petitioner’s case was transferred to              
          Appeals Officer Troy Talbott, who continued to investigate                  
          petitioner’s case and to communicate in writing and by telephone            
          with petitioner’s representative and with petitioner.  According            
          to the Appeals Office case activity records, at various times               

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Last modified: November 10, 2007