- 9 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007