Albert Horton and Ramona Osborne - Page 8

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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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