Edward H. Jones, III - Page 19




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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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