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Each attachment indicates that the only issue raised by
petitioner was the disallowance of his claimed mileage expenses
and states in pertinent part:
The only issue raised by the taxpayer is the fact that
his mileage was not allowed * * *
Since taxpayer was issued a Statutory Notice of
Deficiency and did not petition Tax Court, this issue
cannot be considered in connection to the CDP hearing.
Taxpayer is not entitled to judicial review of the
items in the Statutory Notice per IRC sec.
6330(c)(2)(B). However, I offered to review his
records and consider his request for adjustment as an
audit reconsideration, apart from the CDP [collection
due process] hearing.
Taxpayer never responded to my letters or telephone
calls.
* * * * * * *
Taxpayer indicated in his request for a CDP hearing
that he didn’t agree with the balance due because the
agent didn’t allow him business miles. I offered
taxpayer an audit reconsideration, apart from the CDP
hearing, but taxpayer did not call or make the
schedule[d] conference. His “mileage records” do not
support an adjustment without further explanation and
clarification.
It appears taxpayer has a history of dropping the ball
– making some contact – then not responding. This
happened during the examination, with collection, and
now in appeals.
The levy balances the need for the efficient collection
of taxes with the legitimate concern of Benedict John
Casey that any collection action be no more intrusive
than necessary, because he has failed to cooperate in
proving the liability is incorrect and failed to offer
any collection alternative.
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Last modified: May 25, 2011