Carol A. Black and William R. Adams - Page 4

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               On April 25, 2001, the Appeals officer sent a notice of                
          determination to petitioners.  The notice determined that                   
          petitioners had not provided a financial statement showing that             
          they could make monthly payments to support their request for an            
          installment agreement.  Accordingly, the Appeals officer                    
          determined that the proposed levy was appropriate.  The notice of           
          determination did not mention the requested abatement of                    
          additions to tax.  The Appeals officer did, however, consider               
          petitioners’ request for abatement of the additions to tax and              
          declined to abate the amounts because he saw no link between the            
          medical condition and either the late filings or the failure to             
          pay the tax shown on the returns.                                           
               Petitioners requested and received a hearing conducted under           
          section 6330.  Section 6330(c)(2) provides:                                 
                    (2) Issues at hearing.--                                          
                         (A) In general.--The person may raise at the                 
                    hearing any relevant issue relating to the unpaid                 
                    tax or the proposed levy, including--                             
                              (i) appropriate spousal defenses;                       
                              (ii) challenges to the appropriateness                  
                         of collection actions; and                                   
                              (iii) offers of collection alternatives,                
                         which may include the posting of a bond, the                 
                         substitution of other assets, an installment                 
                         agreement, or an offer-in-compromise.                        
                         (B) Underlying liability.--The person may                    
                    also raise at the hearing challenges to the                       

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