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would precede any subsequent judgments, and may be
ahead of those already on file * * * [Reproduced liter-
ally.]
The settlement officer also concluded that petitioner did not
have sufficient income to fund an installment agreement.
On June 20, 2005, in response to the settlement officer’s
requests in the settlement officer’s March 21, 2005 letter,
petitioner’s authorized representative mailed to the settlement
officer copies of (1) petitioner’s check in payment of estimated
tax due on April 15, 2005, and Form 1040-ES, Payment Voucher 1,
for petitioner’s taxable year 2005 and (2) a bill from the
Internal Revenue Service (IRS) that appears to relate to peti-
tioner’s Federal tax liability for 2004 and a check signed by
petitioner in payment of that bill.
On June 22, 2005, the settlement officer held a telephonic
conference with petitioner’s authorized representative (June 22,
2005 conference). During that conference, petitioner’s autho-
rized representative agreed that petitioner was unable to fund an
installment agreement. The settlement officer indicated that an
offer-in-compromise would probably not be accepted because of
petitioner’s equity in the real properties. Nonetheless, peti-
tioner’s authorized representative indicated that petitioner
still wished to submit an offer-in-compromise.
On June 22, 2005, the settlement officer sent to peti-
tioner’s authorized representative the materials needed for
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