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petitioner would have been amenable to collection alternatives
other than the $100 offer in compromise that she had submitted.
The statute, however, contemplates that the taxpayer raise at the
hearing relevant issues, including offers of collection
alternatives. Sec. 6330(c)(2)(A)(iii). The statute requires the
Appeals officer only to consider the “offers of collection
alternatives” raised and information presented by the taxpayer.
See, e.g., Crisan v. Commissioner, T.C. Memo. 2003-318; Willis v.
Commissioner, T.C. Memo. 2003-302; O’Brien v. Commissioner,
T.C. Memo. 2003-290; Schulman v. Commissioner, T.C. Memo. 2002-
129. It does not require continuous negotiation. In reviewing
the determination made by the Appeals Office, we are limited to
reviewing the information that petitioner presented. Having
reviewed the financial data in the record, we conclude that it
was not an abuse of discretion to reject the $100 offer in
compromise.
Petitioner also complains that there was no review within
the Appeals Office and that there was an abuse of discretion by
the Appeals officer in not referring the offer in compromise
evaluation to IRS collection personnel, with whom petitioner’s
representative had experience. In some cases, assistance from
revenue officers may be sought. See, e.g., Van Vlaenderen v.
Commissioner, T.C. Memo. 2003-346. Petitioner does not have a
right under section 6330, however, to more than one hearing or to
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