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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 to
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