- 13 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: March 27, 2008