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received on January 4, 2002. Your request was not received
timely for 1998. You are entitled to an equivalent hearing
only for the proposed levy action for this year. * * *
On October 17, 2002, respondent also sent petitioners a
notice of determination for 1999. The “Summary of Determination”
stated:
It has been determine [sic] that no relief is to be granted
and that the proposed enforcement action (levy) is
sustained. You failed to provide additional financial
information as requested in order for us to consider your
request for an installment agreement.
The attachment to the notice of determination stated:
On your Form 12153, you requested the continuation of a
payment plan. You raised no other issues on your written
protest.
Subsequent to making your request for a Collection Due
Process Hearing, you submitted an Offer in Compromise, Form
656 under doubt as to collectibility effective tax
administration. Your offer was received February 11, 2002.
The Settlement Officer assigned to your case returned your
offer because you were not in compliance with filing
required tax returns. We had no record of your Form 1065
being filed for 1998 for Orum & Roth. The offer was
returned with a letter dated June 20, 2002 explaining this.
Keith Orum contacted the Settlement Officer on July 17,
2002 to confirm the telephone conference and declined a
face-to-face conference. The Settlement Officer reviewed
her letter with Keith explaining the reasons why the offer
would not be accepted. Those reason [sic] are as follows:
• The reason you provided for Effective Tax
Administration does not meet the economic hardship
criteria.
• Based upon the financial information you provided it
appears you have the ability to pay the liabilities in
full within the statutory period for collection
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