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response to the two NFTLs they had received, the Gillespies filed
with Appeals a second Form 12153. They stated their disagreement
with the NFTLs in the same terms they had used to disagree with
the final notice. On April 27, 2004, in response to both the
final notice and the NFTL he had received, the trustee filed with
Appeals a Form 12153. He stated his disagreement with the final
notice and the NFTL in the same terms the Gillespies had used.
Mr. Jones signed all of the Forms 12153 as petitioners’
authorized representative.
On August 24 and 26, 2004, in response to the Forms 12153,
an Appeals employee, Settlement Officer Catherine H. Watkins (the
settlement officer), sent Mr. Jones similar letters scheduling
hearings to be held on September 22, 2004, by telephone. In her
letters, the settlement officer stated that, at the hearing,
petitioners could discuss, among other things, collection
alternatives. She instructed Mr. Jones that, for her to consider
collection alternatives, including an offer-in-compromise,
petitioners would have to (1) file returns for 2001, 2002, 2003,
and, for the trust, 2000, which IRS records indicated had not
been filed, and present her with signed copies, and (2) provide
her with completed collection information statements. She
enclosed the required forms and asked Mr. Jones to send her the
items within 14 days of the date of the letter.
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Last modified: November 10, 2007