- 4 - On June 21, 2004, Troy Talbott, the Appeals officer handling the case, sent Wells a letter stating that he had started the CDP review and that Wells had until July 8--just twelve business days--to file Industrial’s overdue tax returns for 1996 and 2001 as well as submit any collection alternatives and current financial statements. Two days later, Wells wrote back to Talbott with a summary of a phone conversation they had earlier that day, and promised to respond to Talbott’s request for documents once he received an account history for Industrial. He added that he would need an extension of the July 8 due date, but did attach copies of Industrial’s 1996 and 2001 tax returns (which had apparently already been filed) to his letter. Talbott, it turned out, had anticipated Wells’s request for an account history and mailed a copy to Industrial even before Wells asked for one. Wells sent Talbott a brief note acknowledging receipt of that history on June 28: 1. Receipt acknowledged. 2. It appears that 1990-1993 is the problem as no deductions. 3. The $1 million income in 1990 never happened. 4. I will be sending you some papers shortly. Talbott understood this note to be an omen that Wells planned to revisit the amount of tax owed, and replied with a letter dated July 1, telling Wells that Industrial could not reargue the underlying liability--it had already brought and settled a Tax Court case for those years. His letter also reconfirmed the July 8 deadline to provide any documentation. With Independence DayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007