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for relief for the period November 14, 2001, through December 13,
2002. We take it that petitioner has abandoned any claim for
abatement for periods before November 14, 2001, the date
petitioner and Krogue first met each other in Krogue’s office.
Under these circumstances, we shall not comment on respondent’s
contentions insofar as they relate to periods before November 14,
2001. Also, petitioner’s claim is entirely under section
6404(e), and he does not claim entitlement to an abatement under
section 6404(f); we shall not comment on respondent’s contentions
regarding section 6404(f).
(1) First Period (Nov. 14--Dec. 13, 2001)
At their November 14, 2001, meeting Krogue told petitioner
that respondent’s policy was to collect payment in full if the
taxpayer had enough assets to satisfy the tax liabilities but
that installment arrangements were possible under certain
circumstances. She told petitioner to submit certain materials
by December 14, 2001. Petitioner mailed the requested material
to Krogue on December 13, 2001. Krogue was engaged in the
process of gathering the information and documentation
appropriate to lay the foundation for a decision as to whether
the IRS should allow petitioner to extend the period for payment
of his acknowledged tax liability. Petitioner’s summary of what
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