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The only collection alternative offered by petitioner during the
process before Appeals was an offer in compromise for $100. No
other issues were raised. We review respondent’s determination
for abuse of discretion. Goza v. Commissioner, supra at 182.
Petitioner asserted during the hearing on the Motion for
Summary Judgment that she was faced with more than $300,000 in
unpaid taxes, that she had rejected a suggestion to pursue
bankruptcy as a means of avoiding her debts, and that she faced
hardship in paying her tax liabilities. She also argued that the
information submitted with the offer in compromise was out of
date and that she was prepared to update the information to
establish her inability to pay.
Petitioner apparently is seeking relief from taxes for other
years that are not involved in the proposed levy and the
determination that is the basis of this proceeding. This case
involves only unpaid liabilities for 1997 and 1998, totaling
approximately $13,600, and not petitioner’s total outstanding tax
obligations. In any event, petitioner’s claims of current
financial hardship cannot be considered in this proceeding
because they were not raised before the Appeals officer. See
Magana v. Commissioner, 118 T.C. 488, 493-494 (2002).
Through the testimony of her representative, petitioner also
attempted to raise a dispute with the facts set forth in
respondent’s Motion for Summary Judgment concerning whether
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