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Petitioner Antonio Thomas telephoned the settlement officer on
November 14, 2001, to postpone this meeting because his
representative was ill, and the scheduled meeting did not take
place. A second meeting was scheduled for December 3, 2001, at
10 a.m. Petitioners failed to appear, and in the afternoon of
that day, a representative of petitioners contacted the
settlement officer to request a further postponement. The
representative was advised that Appeals would close the case and
issue a determination.
On December 12, 2001, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (determination letter). Therein, the settlement
officer first determined that all applicable laws and
administrative procedures had been met for all liabilities at
issue except for the 1985 taxable year; for 1985, the settlement
officer determined that petitioners’ liability had been
discharged in the bankruptcy proceeding. With respect to issues
raised by petitioners, the determination letter concluded that
all of the issues raised by petitioners related to the validity
of the assessments and that all of the assessments except for the
one relating to 1985 were valid. Finally, the determination
letter concluded that the proposed collection action
appropriately balanced petitioners’ interests with the need for
efficient tax collection, noting a “pattern of unresponsiveness”
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