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and a return envelope for your convenience.
Mr. Gazi and Ms. Gazi’s estate did not submit Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals (Form 433-A), within 14 days of the date of
the settlement officer’s March 27, 2006 letter, i.e., by April
10, 2006.
On April 18, 2006, Ms. Ciraolo called the settlement officer
to reschedule the Appeals Office hearing that the settlement
officer offered Mr. Gazi and Ms. Gazi’s estate in the settlement
officer’s March 27, 2006 letter. During that conversation, the
settlement officer agreed to reschedule the Appeals Office
hearing from April 25 to May 15, 2006.
On May 15, 2006, Ms. Ciraolo called the settlement officer.
The settlement officer made the following pertinent entries in
his “Case Activity Records” with respect to that call:
TC from POA [Ms. Ciraolo]. She said she did not have
the 433A complete and would like to delay conference
for at least another week. I advised that was not
acceptable since we already delayed the conference
once. She had no info to present. I advised her when
she has her 433A completed she can submit it with a
request for an IA thru Compliance. She then said their
issue is the same, the money is not owed. I advised I
will agree with the previous decision by the court the
money is owed and the RO’s action was correct. Since
an alternative could not be agreed upon, I will issue a
determination letter. [Reproduced literally.]
On May 17, 2006, the Court of Appeals for the Eleventh
Circuit remanded the Gazis’ Tax Court case to the Court for a
ruling on the motion for reconsideration of the July 28, 2005
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Last modified: March 27, 2008