Ella Louise Wooten - Page 6

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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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