Mohammed Ali Gazi and Estate of Raees Iftekhar Gazi, Deceased, Mohammed Ali Gazi, Personal Representative - Page 13




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               collection alternatives and offering you a face-to-face                
               or telephone conference at the Appeal’s Office in                      
               Baltimore, Md. on 04/25/2006.                                          
               On 04/18/2006 I received a request from your power of                  
               attorney to reschedule the conference to allow addi-                   
               tional time to prepare the requested financial state-                  
               ment.  We agreed to reschedule for 05/15/2006 at 10:30                 
               a.m.                                                                   
               On 05/15/2006 I received a call from your power of                     
               attorney to request an additional delay to complete the                
               financial statement, I denied this request.  Your power                
               of attorney stated she was not ready for the confer-                   
               ence.  I advised based on the delay at this conference                 
               and the previous delays, I would issue a determination                 
               letter to fully sustain the action by the Compliance                   
               Division.  Your power of attorney then stated she                      
               wished to protest the liability based on the appeal                    
               filed in the Tax Court.  I denied that request based on                
               the Tax Court decision that the assessments are valid.                 
               Your power of attorney claimed I did not respond to her                
               request for additional time from a message she left me                 
               last week.  The voice mail message was left at 6:30                    
               p.m. Sunday 05/14/2006.  I received a fax after the                    
               conference from your power of attorney showing the                     
               Court of Appeals has requested the Tax Court to rule on                
               the timely tolling motion for reconsideration of your                  
               motion.  This does not change my determination to fully                
               sustain the action by the Compliance Division.  I                      
               advised your power of attorney, since you did not                      
               supply any financial information to review, I could not                
               consider an alternative to collection action.                          
               You are being advised of this determination to sustain                 
               the action by Compliance in full and your right to                     
               judicial review.                                                       
                            III.  DISCUSSION AND ANALYSIS                             
               1.  VERIFICATION OF LEGAL AND PROCEDURAL REQUIREMENTS                  
               From all available information, the compliance file                    
               indicates that the requirements of applicable law or                   
               administrative procedures have been met.                               
               The assessment was made on the applicable CDP notice                   
               period per Internal Revenue Code (“IRC”) Section 6201.                 






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