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Petitioner did not respond by September 19, 2005, to the
second offer specialist’s September 6, 2005 letter. On September
20, 2005, the second offer specialist returned petitioner’s June
24, 2005 offer-in-compromise to the settlement officer and
recommended that it not be accepted.
On September 23, 2005, Mr. Silverberg sent a note by facsim-
ile to the settlement officer and the second offer specialist.
In that note, Mr. Silverberg stated in pertinent part:
I am writing to request an extension of time until
October 14 for Mr. Lloyd to respond to * * * [the
second offer specialist’s] letter of 9/6/05. My sched-
ule has been full and I have until now been unable to
confer with him about providing additional information
for you to consider. Thank you in advance for your
consideration.
On September 27, 2005, Mr. Silverberg sent another note by
facsimile to the settlement officer and the second offer special-
ist. In that note, Mr. Silverberg stated in pertinent part:
Please grant Mr. Lloyd additional time to get back to
you through * * *, his accountant. * * * [petitioner’s
accountant] will be sending you a new Power of Attorney
to discuss both Henry M. Lloyd PC and Mr. Lloyd’s
individual accounts. If you have any questions before
receiving the new Power, please contact me.
On November 9, 2005, the settlement officer sent a letter to
petitioner. In that letter, the settlement officer stated in
pertinent part:
I have scheduled a telephone conference call for you on
December 6, 2005 at 10:00AM. This call will be your
CDP hearing.
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Last modified: March 27, 2008