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discussing this matter with our client, he has requested that we
pursue a collection alternative on his behalf. Our client would
like to pursue an Offer and Compromise.” Respondent contends
that petitioner did not send the alleged March 4, 2002, letter.
Section 6330(c)(2)(A)(iii) requires the Commissioner’s
Appeals officer to consider “offers of collection alternatives,
which may include posting of a bond, the substitution of other
assets, an installment agreement, or an offer-in-compromise.”
See Goza v. Commissioner, 114 T.C. 176, 180-182 (2000). We
review the Commissioner’s determinations under section
6330(c)(2)(A)(iii) under an abuse of discretion standard. Sego
v. Commissioner, 114 T.C. 604, 609-610 (2000); Goza v.
Commissioner, supra.
The correspondence between petitioner and the Appeals
officer indicates that respondent was aware that petitioner was
interested in seeking an offer in compromise. Respondent
included the offer in compromise materials in the January 23,
2002, letter to petitioner. Petitioner’s January 30, 2002,
letter requested an extension of time to file a response to that
letter. The notice of determination refers to such an extension
of time to file a response. Petitioner contends that his March
4, 2002, letter stated that he wanted to seek an offer in
compromise or enter into a collection alternative with
respondent.
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