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in the administrative record because petitioners’ financial
circumstances had changed.
Petitioners’ representative agreed to provide the Appeals
officer with updated financial statements from petitioners by
December 31, 2001, but never did so. The lack of an updated
financial statement compelled the Appeals officer to use the
financial statement and the information on petitioners’ taxable
year 2000 income tax return to determine petitioners’ eligibility
for the proposed installment agreement. The Appeals officer
determined that certain expenses petitioners claimed on the
financial statement were not allowable under the provisions of
the IRM. Therefore, the Appeals officer could not take those
expenses into account in determining how much petitioners were
able to pay.
5. Notices of Determination and Decision Letter Issued
for the Taxable Years 1997-99
On March 21, 2002, respondent issued a final notice of
determination upholding the Federal tax lien for the taxable
years 1997-99. Respondent also issued a notice of determination
upholding the Federal tax levy for the taxable year 1999.
Further, respondent issued a decision letter concerning the
equivalent hearing under section 6330 for the taxable years 1997
and 1998 in which respondent upheld the proposed levy actions.
At the time the notices were issued, petitioners’ outstanding
income tax liability was $55,362.13. In analyzing petitioners’
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