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taxpayers’ original audits for 1984 and 1985 and the
penalties and interest assessed.[1] The taxpayer has
fully paid those tax years and copies of the lien
releases were provided to the taxpayer. Those tax
years do not fall under the Due Process Procedures.
Any claims for abatement of penalties and interest
should be made under the appropriate method of filing.
The lien notices for 1987, 1988, and 1990 were
filed on 8/18/94 and are not subject to appeal under
IRC Section 6320.
The taxpayer has not raised any possible collec-
tion alternative.
Balancing Efficient Collection and Intrusiveness
The revenue officer issued L 1058 after identify-
ing levy sources. Repeated requests were made for
financial statements and they were not provided nor has
the taxpayer raised any possible collection alternative
for these years. It is his contention that prior years
are overpaid, yet no evidence has been provided to
verify that any possible overpayments not previously
addressed would full pay these tax years. Therefore,
since the taxpayer has not provided any financial
statements to determine if there may be a less intru-
sive method of collection, the District should proceed
with levy enforcement.
1The record does not contain a copy of the attach-
ment to petitioner’s Form 12153.
OPINION
Petitioner contends that respondent has not accounted for
all of the payments that he made to the IRS with respect to his
taxable years 1984, 1985, 1986, 1987, and/or 1990.6 According to
petitioner, if respondent had properly accounted for all such
6Although given the opportunity to do so, petitioner did not
file any briefs in this case. Our understanding of petitioner’s
position is based upon his opening statement and his testimony at
the trial in this case.
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