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Petitioner sent no further communications to Appeals Officer
Grantham, and, accordingly, no further information was advanced
about any particular collection alternative. On January 11,
2005, the Notice was sent to petitioner, and he timely instituted
this proceeding on February 9, 2005. In essence, the Notice
explained that because a review of petitioner’s assets revealed
that he had sufficient equity to pay the tax liability in full,
there was no prospect for the consideration of an offer-in-
compromise. The Notice also indicated that petitioner stated
that he would consult with his C.P.A. and advise respondent about
ways to gain a tax advantage from coordination of levies, but
petitioner failed to provide this information. Also reiterated
in the notice of determination, was that petitioner had declined
to discuss “the issues * * * [he] raised in * * * [his] request
for a hearing”. The Notice concluded with the determination that
the filing of the NFTLs with the Panola County Chancery Clerk’s
Office in Batesville, Mississippi, for petitioner’s 1991 income
tax liability was sustained.
In addition to the above Notice, respondent sent the
following Letters to petitioner regarding his 1991 tax liability:
1. Letter CP-14: Sent on or about November 9, 1998, which
normally contains payment history and contact telephone numbers.
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Last modified: November 10, 2007