Dimitrios T. Manousos and Anne M. Manousos - Page 5




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          final notice to petitioners in respect of their outstanding                 
          liability for 2002, which, at that time, was approximately $1,407           
          (without regard to statutory accruals of interest and penalty).             
          Administrative Developments                                                 
               Petitioners timely filed with respondent a Form 12153,                 
          Request for a Collection Due Process Hearing.  In the Form 12153,           
          petitioners focused only on the existence or amount of their                
          underlying liability.                                                       
               By letter dated August 16, 2006, respondent’s settlement               
          officer advised petitioners that, inter alia:                               
               For me to consider alternative collection methods such                 
               as an installment agreement or offer in compromise, you                
               must provide any items listed below.  In addition, you                 
               must have filed all federal tax returns required to be                 
               filed.                                                                 
          The “items listed below” included a completed Collection                    
          Information Statement (Form 433-A for individuals and/or Form               
          433-B for businesses) and signed income tax returns for 2003,               
          2004, and 2005.  Regarding the latter, the settlement officer               
          stated that “Our records indicate they have not been filed”.                
               The settlement officer subsequently conducted a telephonic             
          conference with Mrs. Manousos.                                              
               Petitioners never submitted a Collection Information                   
          Statement or proposed a specific collection alternative, nor did            
          petitioners file all of the requested returns during the time               
          that their case was pending before respondent’s Appeals Office.             







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