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light of the refunds that petitioner anticipated he was to
receive from the filing of amended returns for taxable years 1999
and 2000, and his Federal income tax return for 2004. Mr.
Callanan contacted Mr. Goldammer and reiterated that petitioner’s
proposal was still unacceptable. In that same conversation, Mr.
Callanan informed Mr. Goldammer that despite his continuing
rejection of petitioner’s proposal, he would “work on
petitioner’s financial statement” and get back to him.
On July 6, 2005, Mr. Callanan contacted Mr. Goldammer and
informed him that because the outstanding liability owed was
below $25,000--$18,277.54, to be precise--he could accept an
installment agreement. Mr. Callanan then proposed that
petitioner agree to make monthly payments of $375. Petitioner
rejected this offer.
The record in this case includes petitioner’s Federal income
tax return for the taxable year 2003. On that return, petitioner
reported wages, salaries, and tips in the amount of $125,979.
Petitioner also reported rental income from six residential and
commercial properties that he owns, including a banquet hall. As
of the time the present motion was filed, petitioner had filed
neither his Federal income tax return for taxable year 2004, nor
any amended returns for 1999 or 2000.
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Last modified: November 10, 2007