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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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Last modified: March 27, 2008