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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.
OPINION
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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Last modified: May 25, 2011