- 30 - find Mr. Penny’s testimony credible on the subject of advisory review, and we note that such review was not one of the required steps enumerated in the IRM. We hold, therefore, that the Appeals Office did not abuse its discretion in determining that the requirements of any applicable law or administrative procedure have been met with respect to the nominee NFTL at issue in this case. A.3. Consideration of Collection Alternatives Petitioner also contends that respondent erred by not considering reasonable collection alternatives to respondent’s nominee NFTL and disputes that the filing of the nominee NFTL properly balanced respondent’s need for efficient collection of taxes with petitioner’s concern that the collection action be no more intrusive than necessary. Petitioner, however, did not submit a completed Form 433-A, Collection Information Statement - Wage Earner, or Form 433-B, Collection Information Statement - Business, to document his claimed inability to pay. Even if petitioner had submitted completed Forms 433-A and 433-B, the disagreement between petitioner and respondent regarding the extent of his ownership interest in the Claremore property precluded any determination of petitioner’s actual ability to pay the unpaid tax liabilities at issue. We also note that petitioner did not offer any collection alternatives that would adequately protect respondent’s need toPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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