- 6 -
2000 were reversed and then reallocated to the 1997 joint tax
liability. Subsequently, the Nicols informed the Appeals officer
that they could not pay their outstanding tax liabilities for
1993 and 1997.
During the CDP hearing, Mrs. Nicol also inquired about the
interest for 1997. The Appeals officer sent Mrs. Nicol INTST2
printouts of her joint tax account with petitioner on February
22, 2002, and again on March 6, 2002. There is no evidence in
the record that either petitioner or Mrs. Nicol ever asked for an
abatement of interest for 1997 or that they ever inquired about
or requested an abatement of the interest for 1993.
D. Notices of Determination
In Notices of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated May 16, 2002, respondent
determined that the legal, administrative, and procedural
requirements for proceeding with collection by lien of
petitioner's income tax had been met.
On June 17, 2002, petitioner timely filed a petition in this
Court challenging the 1993 deficiency and alleging that
respondent failed to offer or discuss collection alternatives.
2An INTST is an internal IRS interest and penalty
computation program. It shows the amount of taxes, tax
penalties, and interest due from or owing to the taxpayer with
respect to a tax account as of a specific date, based upon both
posted and pending transactions. Kay v. IRS, 82 AFTR 2d 6138,
98-2 USTC par. 50,707 (C.D. Cal. 1998), affd. without published
opinion 225 F.3d 663 (9th Cir. 2000).
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