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his estimated tax payments for 2001 establish petitioner’s
failure to be in current compliance with his Federal income tax
liabilities and support respondent’s determination to disapprove
of petitioner’s offer in compromise.
Relying on respondent’s temporary regulations under section
7122, petitioner asserts that respondent’s Appeals officer, prior
to rejecting petitioner’s offer in compromise, failed to have her
proposed rejection of the offer in compromise reviewed by an
“independent reviewer”. See sec. 301.7122-1T(e)(2), Temporary
Proced. & Admin. Regs., 64 Fed. Reg. 39026 (July 21, 1999).
Petitioner apparently believes that respondent’s Appeals
officer manager who reviewed the Appeals officer’s determination
to reject petitioner’s offer in compromise does not qualify as an
“independent” reviewer under the above statute and regulation.
To the contrary, in the context of a collection hearing before
respondent’s Appeals Office, the prescribed independent
administrative review of a proposed rejection of an offer in
compromise generally is to be performed by an Appeals manager,
which in this case occurred on August 7, 2001. 4 Administration,
Internal Revenue Manual (CCH), sec. 8.7.2.3.5(3)(f), at 27,282
(Nov. 13, 2001), promulgated under the legislative authority of
sec. 7122(d).1
1 4 Administration, Internal Revenue Manual (CCH), sec.
8.7.2.3.5(3)(f), at 27,282 (Nov. 13, 2001), among other things,
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