- 19 - 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 whatPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: March 27, 2008