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Services in partial satisfaction of outstanding child support
obligations, and that respondent also acted improperly in
transferring an overpayment credit in her 1995 tax account to the
Department of Agriculture.
During respondent’s consideration of the Form 12153
described above, respondent’s Appeals officer obtained an IRS
“TXMODA - Transcript of Account” in regard to each of
petitioner’s 1995, 1996, and 1997 tax years. From those
transcripts the Appeals officer verified that all applicable laws
and administrative procedures were satisfied. In no document
relevant to this case and at no hearing relevant to this case did
petitioner, with the exception of the disputed issue described
above, allege either that respondent failed to meet all
applicable law and administrative procedures or that respondent’s
Appeals officer failed to verify that respondent satisfied all
applicable laws and administrative procedures as required by
section 6330(c)(1). Nor did petitioner raise any spousal
defenses, any challenges to the appropriateness of collection
actions, or any offers of collection alternatives to respondent’s
Appeals officer.
Respondent held a hearing in regard to the Form 12153 filed
by petitioner. After that hearing, respondent sent petitioner an
IRS Form 3193 - NOTICE OF DETERMINATION CONCERNING COLLECTION
ACTION(S) UNDER SECTION 6320 and/or 6330, dated March 21, 2002,
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