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again rescheduled for November 3, 2004, and on November 1, 2004,
petitioner called and requested a further rescheduling to
November 9, 2004. On November 9, 2004, petitioner telephoned
Appeals Officer Grantham and indicated that he had suffered an
injury, and the hearing was finally scheduled for November 16,
2004.
The hearing was held on November 16, 2004, and the following
general topics were discussed: (1) The Appeals process and the
then outstanding amount of petitioner’s 1991 tax liability; (2)
collection alternatives, such as offers-in-compromise and
installment payment plans, were limited due to the fact that
petitioner’s net worth was sufficient to pay his entire 1991 tax
liability; (3) the possibility of respondent’s collecting the
entire amount of the 1991 tax liability from petitioner’s equity
in a retirement account, and a possible tax advantage from
coordination of levies by respondent on that account; (4)
petitioner declined any additional discussion of his 13 items of
disagreement which he had listed on the Form 12153, but he
reserved the opportunity to detail his disagreement in a
subsequent writing; (5) petitioner advised that he would consult
with his certified public accountant (C.P.A.) to determine what
was in his best interest and notify Appeals Officer Grantham by
the end of the week.
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