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collections action be rescinded on the grounds that the
outstanding liabilities from taxable years 1999 and 2000 would
ultimately be satisfied by one of two ways: (1) through a refund
petitioner anticipated as a result of his yet-to-be-filed amended
returns for taxable years 1999 and 2000; or (2) through a refund
petitioner anticipated from his yet-to-be-filed Federal income
tax return for taxable year 2004. Mr. Callanan rejected
petitioner’s proposal on the basis that petitioner had yet to
file any of the returns proposed, and because any refund would,
at that point, be purely speculative, there would be no way to
assure that refunds would repay the liabilities owed. In the
alternative, Mr. Callanan raised the possibility that petitioner
might be able to enter into an installment agreement.
Petitioner, however, stated that he would not be financially able
to accept such an arrangement. The CDP hearing concluded without
further mention of collection alternatives.
On February 4, 2005, Mr. Callanan met with Mr. Goldammer to
review petitioner’s financial statement. At this meeting, Mr.
Goldammer protested that such a review was not necessary as the
refunds that petitioner anticipated receiving would cover his
outstanding liabilities owed.
On February 14, 2005, Mr. Goldammer left a voicemail message
on Mr. Callahan’s voicemail system, reiterating petitioner’s
position that the collection action should be abandoned in the
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Last modified: November 10, 2007