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“Notice of Levy/Seizure (Explain why you don’t agree. Use extra
sheets if necessary.)”. By fax transmitted August 4, 2003,
petitioner submitted a partially completed Form 433-A to the IRS.
The Appeals Officer concluded that information as to income
received by petitioner’s wife was omitted from the financial
statement. The Appeals Officer conducted a telephone conference
on August 5, 2003, wherein petitioner was advised that the
financial statement failed to include full financial information
of the household. Petitioner advised the Appeals Officer that he
would not be interested in an installment agreement for an amount
that exceeded $50 per month. On August 15, 2003, the Appeals
Officer issued the notice of determination advising that there
were no collection alternatives available.
Based on this record, we conclude that respondent did not
abuse his discretion. Respondent determined that petitioner did
not submit complete or accurate information to respondent.
Respondent gave petitioner an opportunity to correct and complete
financial information, yet petitioner failed to do so.
Petitioner has failed to raise a spousal defense or make a valid
challenge to the appropriateness of respondent’s intended
collection action. These issues are now deemed conceded. See
Rule 331(b)(4). Accordingly, we conclude that respondent’s
determination was not an abuse of discretion.
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Last modified: May 25, 2011