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tax filings.” Petitioner emphasizes that, contrary to the
determination of the Appeals officer, he “has filed all of
his prior tax returns, including a validly filed automatic
extension for his 2003 tax return and the 2003 return
itself.” Petitioner acknowledges that his attorney had
thought that his tax liability for the year was $70,000.
Petitioner notes that, in fact, the liability “was actually
much lower and taxpayer has paid the liability.”
Second, petitioner asserts that the Appeals officer
abused her discretion because she “summarily rejected” the
offer-in-compromise “and demanded the taxpayer enter into
an installment agreement.” According to petitioner the
Appeals officer took this action “without making the
required financial analysis.” Petitioner contends that the
Appeals officer “rejected this offer outright because the
taxpayer’s OIC (offer-in-compromise) showed the ability to
pay the taxes in full.” Petitioner complains that
the IRS failed to even consider what affect [sic]
on the taxpayer, and his family, would be [sic]
by him using his meager retirement account to
satisfy the tax obligation, and insisted that the
2003 obligation be cured, and that a sub-stantial
down payment be made on the 2000 and 2001 tax
liability amounting to $139,000.00 as of June 1,
2004.
Petitioner also complains that the Appeals officer failed
to take into account the “schedules of national and local
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