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allowing all of the expenses claimed by petitioner in his
financial forms and were calculated in accordance with the IRS
Manual. Petitioner did not accept any of Wallace’s proposals.
On March 8, 2002, Wallace wrote to Zerjav suggesting a
resolution of the section 6330 proceeding, wherein collection of
petitioner’s 1993, 1994, and 1995 income tax liabilities would be
held in suspense until petitioner’s income exceeded $35,000 per
year. Petitioner did not accept that proposal. On May 29, 2002,
Wallace met with Zerjav and discussed collection alternatives.
Zerjav insisted on an offer in compromise in the amount of $100
and offered no other collection alternatives.
On June 11, 2002, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was sent to
Zerjav as petitioner’s representative. The determination was
summarized as follows:
The decision by Appeals is that this account is to be
placed in currently not collectible (CNC) status based
on the taxpayer’s current financial situation. The
taxpayer’s account should be revisited when his income
exceeds $35,000. As a result of this action, levies
will not be pursued.
The petition in this case disputed consideration of
petitioner’s mother’s income by the Appeals officer and other
details of the Appeals officer’s analysis and complained of the
lack of “independent review” of the rejection of the offer in
compromise. The petition also alleged:
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