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We may also consider whether you owe the amount due,
but only if you have not otherwise had an opportunity
to dispute it with Appeals or did not receive a
statutory notice of deficiency.
We will balance the IRS’ need for efficient tax
collection and your legitimate concern that the
collection action be no more intrusive than necessary.
Finally, Hopkins asked that petitioner forward to the IRS by
October 28, 2005, a statement providing specific reasons about
the IRS actions with which he disagrees and a collection
alternative; all appropriate documents necessary to consider any
collection alternative, including a completed Form 433-A,
Collection Information Statement for Wage-Earners and Self-
Employed Individuals; and copies of filed Federal income tax
returns for 1999, 2003, and 2004. Petitioner was informed that,
if he did not respond to the letter by the deadline, the
determination would be based on his request, any information he
previously provided, and the IRS’s administrative file and
records.
Petitioner did not send the required statement, collection
alternative, documents, or returns. Instead, he sent a letter
dated October 8, 2005, with statements and requests nearly
identical to those made in his previous correspondence with the
IRS. A notice of determination was sent to petitioner on
December 7, 2005. The determination was summarized as follows:
Our decision is not to grant you relief * * * from the
proposed collection action. You failed to offer an
acceptable alternative resolution.
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