Henry M. Lloyd - Page 35




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               Please call me at * * * the date and time indicated                    
               above.                                                                 
               Your offer in compromise will not be recommended for                   
               acceptance and we need to discuss other alternatives                   
               [sic] means for payment such as full payment or an                     
               installment agreement.                                                 
               On November 14, 2005, at 1:02 p.m., Stephen P. Kauffman (Mr.           
          Kauffman) sent a letter by facsimile to the settlement officer              
          (Mr. Kauffman’s first November 14, 2005 letter).  In that letter,           
          Mr. Kauffman stated in pertinent part:                                      
                              Re: Henry M. Lloyd * * *                                
                                   Henry M. Lloyd, P.C. * * *                         
                 *       *       *       *       *       *       *                    
                    I have been retained to represent the above-refer-                
               enced taxpayers in matters pending before the Internal                 
               Revenue Service.  Enclosed you will find two (2) powers                
               -of-attorney, form 2848, pursuant to which these tax-                  
               payers have authorized me to represent them.[21]  I                    
               understand that a Collection Due Process Hearing is                    
               currently scheduled for December 6, 2005 at 10:00 a.m.                 
               to review levies that have been issued to Mr. Lloyd                    
               personally, and that offers-in-compromise are pending                  
               for both taxpayers.  Earlier today, I sent you a copy                  
               of a CDP request I filed in connection with levies                     
               issued to Henry M. Lloyd, PC.                                          
                    * * * I am planning to contact * * * the [second]                 
               Offer Specialist assigned to determine the RCP of these                
               matters to discuss his calculations. * * *                             



               21Only Form 2848, Power of Attorney and Declaration of                 
          Representative (Form 2848), appointing Mr. Kauffman as the                  
          attorney-in-fact for petitioner is attached to the copy of Mr.              
          Kauffman’s first November 14, 2005 letter that is in the record.            
          Form 2848 appointing Mr. Kauffman as the attorney-in-fact for               
          Henry M. Lloyd, P.C., is not attached to the copy of Mr.                    
          Kauffman’s first November 14, 2005 letter that is in the record.            





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