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The taxpayers have made only one payment on these taxes
since they were assessed. That payment was for $150.00
dated September 15, 1999. The taxpayers have made no
further attempt to resolve this liability. When con-
tacted by the Automated Collection Site (ACS) they
refused to cooperate or discuss collection alterna-
tives. This prompted the filing of the NFTL by ACS who
was assigned this case.
The records of the Service indicate that the taxpayers
continue this pattern of filing zero income, zero tax
due returns. * * *
The taxpayers raised no other non-frivolous issues.
Balancing the Need for Efficient Collection with Tax-
payer Concerns
The requirements of all applicable laws and administra-
tive procedures have been met. The courts have previ-
ously addressed the taxpayers’ arguments, and Appeals
does not have the authority for reconsideration of the
matters.
* * * * * * *
The taxpayers received their required notices and the
filing of the NFTL was done in accordance with legal
and procedural guidelines and is not subject to with-
drawal or release. The taxpayers have made no attempt
to resolve these liabilities since they were assessed.
The filing of the NFTL was appropriate to protect the
Government’s interest. The taxpayers chose to conclude
the due process hearing prior to any discussion of the
facts of the case or of collection alternatives.
Lacking the taxpayer’s cooperation and based on their
history of non-compliance, the proposed collection
action balances the need for efficient collection of
taxes with the taxpayer’s legitimate concern that any
collection action be no more intrusive than necessary.
[Reproduced literally.]
On August 14, 2002, petitioners filed a petition with the
Court for review of petitioners’ notices of determination with
respect to petitioners’ unpaid liabilities for 1997 and 1998.
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