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suggested that petitioners complete Form 433-A, Collection
Information Statement for Individuals, with supporting
documentation reflecting financial information. The Appeals
officer advised that such information was required to consider
“currently not collectible” (CNC) status.
On the same date as the scheduled conference, petitioner
asked if he could record the conference. The Appeals officer
indicated that petitioner could not record if the conference was
conducted on that day, since the Appeals officer had received
insufficient notice of the request to record. A telephone
hearing was conducted by the Appeals officer with petitioner and
his representative, Mark DeBenedetti. Petitioners and Mr.
DeBonedetti did not submit any additional financial information
to the Appeals officer. Petitioner advised the Appeals officer
that he had been told by a representative of the Taxpayer
Advocate Service that the joint tax liability would be placed in
CNC status and that as a result, no notice of Federal tax lien
would be filed.
IRS records do not reflect that petitioners’ account was
ever placed in CNC status. The Appeals officer explained to
petitioner and Mr. DeBenedetti that the notice of Federal tax
lien would remain in place, even if petitioners were placed in
CNC status. The Appeals Officer also advised petitioner that
petitioners could submit another OIC.
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Last modified: May 25, 2011