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that she still wanted to propose an offer in compromise. The
Appeals officer asked petitioner to submit a completed
Form 433-A.
On August 5, 2002, the Appeals officer still had not
received a Form 433-A from petitioner and had not heard from her
since July 11, 2002. On August 5, 2002, the Appeals officer
administratively closed petitioner’s case for a determination
based upon the information in her file. On August 8, 2002, the
Appeals officer received a package from petitioner containing a
completed Form 433-A and related financial documents (the offer
in compromise materials). The Appeals officer considered the
offer in compromise materials to be late, and he did not review
the information. On August 12, 2002, the Appeals officer issued
a Notice of Determination. The Notice of Determination stated
that petitioner did not have an offer in compromise pending at
this time and set forth the following rationale for preceding
with the levy:
Although a levy is intrusive, since the information
related to the taxpayer’s financial specifics were not
provided so that we might evaluate the collection
alternative, the proposed collection action balances
the need for the efficient collection of the taxes with
the legitimate concern of the taxpayer that any
collection action be no more intrusive than necessary.
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Last modified: May 25, 2011