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taxpayer does not appear to be in filing compliance, no
collection alternatives can be considered at this time.”
Finally, the attachment to the determination deals
with the issue of the balance between efficient collection
action and a taxpayer’s concern that any collection action
be no more intrusive than necessary. According to the
attachment, no alternatives to collection could be
considered at this time because “The taxpayer does not
appear to be in filing compliance”.
Petitioner filed a timely petition in this Court for
judicial review of the Appeals officer’s determination.
In paragraph 4 of the petition, which asks for “the relief
requested and the reasons why you are entitled to such
relief”, petitioner states as follows:
I’m homeless, not working and in recoverey [sic]
from drug abuse, but I’m in scool [sic] tring
[sic] to get back on track. I ask that the $60
fee be waive [sic], do [sic] to the fact I’m
homeless and have no job.
We highlight two aspects of the petition. First,
the petition does not raise an issue about petitioner’s
underlying tax liability for any of the years in issue.
In fact, petitioner appears to have conceded his underlying
tax liability when he stated in his request for the CDP
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Last modified: May 25, 2011