This is just really strange...

[gottago]

On Saturday, I received some communication from the IRS related to a CDPH request we submitted last fall in relation to some threats of levy we received related to our liability for 2006 which was not included in the original OIC. According to the attorney, the OIC was amended by them in April 2007 to include the 2006 liability but either the IRS never received the amended OIC or the attorney lied about sending it. About 65% of the 2006 liability was a result of the levy of my IRA account in 2006 after the OIC was submitted. We had no way to pay this liability but did file an accurate return as instructed by the attorney.

Anyway, the appeals officer scheduled the CDPH and additionally stated that if we wanted the 2006 liability to be designated CNC we just needed to fill out a form 12257 (Summary Notice of Determination, Waiver of Right to Judicial Review of a CDP Determination and Waiver of Suspension of Levy Action) and return it to him with no hearing or other action needed.

Now, here is the really strange part. Also included in the envelope was a 55 page document titled an "ICS HISTORY TRANSCRIPT" that covers dates from 3/19/2005 until 4/10/2008 and is basically the "notes" on our case written by the various IRS employees that we have had contact with during that time. I have NO IDEA why we received this but it does make really interesting reading and explains a few things. We have never received anything like this in the past.

Among other things, it says that our OIC was never "loaded" into the system and to this point has not been rejected. There is also some documentation of contact between the RO and the attorney related to the IRA levy. The RO wrote that "based on the several million dollars that the system shows as taxable income in 2002/2003 I see no reason why they should not have plenty of money now--also where did the money go???" even though she had already met with us months prior during the summons and knew the truth regarding the online trading. Shortly after this was when I refiled the returns with the schedule D's (June 2007) and now, 10 months later the returns have still not been processed.

There is also a very interesting entry dated 3/20/2007 by the RO:

While I was going through drawers I found the CDPs the TPs filed last year. The files are ready to go to Appeals. Apparently I put them in a drawer and didn't forward them.

So this explains a lot--the CDP requests were "in a drawer" for 9 months which is why it took 1 1/2 years for the CDPH to occur. I am sure it is purely coincidental that the time limit for requesting return of levied property is 9 months and that by the time the CDPH was actually held and the determination that the levy action that occurred "was not sustained" by Appeals it was to late to request return of the wrongfully levied property.

Does anyone here have any idea why the appeals officer would send us this transcript? It just seems like something the IRS would not make available and I have no idea why it was sent to us.

Gottago

PS: HAPPY TAX DAY

[gottago]

Oh, I almost forgot...

This transcript thing has a lot of abbreviations (??acronyms) and refers to various numbered "statuses" --is there a centralized place accessible to the public that explains what all these abbreviations stand for and what the various statuses are? Thanks!!

Gottago

[Nikki]

It seems that the Taxpayer Advocate might just be your friend in interpreting what you received and how it impacts you.

The worse thing that could happen is for them to tell you to go away -- which costs 00.00.

[Quixote]

Does anyone here have any idea why the appeals officer would send us this transcript?

I have no doubt that it was sent to you in error. A more interesting question would be why the settlement officer had it in the first place. Rev. Proc. 2000-43 prohibits ex parte communicationd between Appeals and other IRS divisions.