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1993, and 1996 taxable years. The history of account section of
the Appeals officer’s supporting statement said: the “IDRS shows
that these CDP account balances are for outstanding balances owed
on their voluntarily filed original and amended returns.
Generally, the taxpayer full [sic] paid the tax, but has not paid
the interest.” Section three of the Appeals officer’s supporting
statement provided:
Balancing the Need for Efficient Collection with Any
Legitimate Concern that the Proposed Collection Action
is more Intrusive than Necessary:
The representative states that the taxpayer is not in
agreement with the final amended return filed on each
period. It was only a protective action taken by the
taxpayer. The taxpayer is pursuing that action to contest
that - including it in his petition to the Tax Court on the
unassessed audit adjustments and also pursuing interest
abatement.
The representative has reviewed transcripts of the
taxpayer’s account and matched their payments - they
have no argument with any payments.
On August 8, 2000, respondent issued petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (Determination), for petitioners’ 1991 taxable year,
which determined that the tax liabilities reported in the final
notice for 1991 were appropriate. The notice of determination
provided:
Summary of Determination:
* * * ** * * *
The outstanding balance owed and shown on the L-1058
dated 03/09/2000 was based on assessments from your
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