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wished to submit collection alternatives, and petitioners stated
that they did not.
On or about September 19, 2002, petitioners submitted an
Offer in compromise (offer) to the IRS’s centralized offer in
compromise unit in New York. The offer related to the unpaid
assessments, and the basis of the offer was “doubt as to
liability”. Petitioners did not provide a copy of the offer to
Appeals Officer Powell. By letter dated January 15, 2003, the
offer was returned to petitioners by the IRS because it could not
be processed in the form submitted. A second offer was submitted
by petitioners’ counsel to the IRS by facsimile transmission on
January 30, 2003.
On January 29, 2003, Appeals sent Notices of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330 to
petitioners’ counsel (the notices of determination). The summary
of determinations section of each of those notices of
determination states:
During Appeals consideration of your case, you were
informed that you could not raise the issue of your tax
liability because you had an opportunity to dispute the
issue and failed to do so. No collection alternatives
were explored because you chose not to submit financial
information to evaluate the collection alternatives.
The section concludes:
Appeals has obtained verification from the Secretary
[of the Treasury] that the requirements of any
applicable law or administrative procedure have been
met, considered any relevant issues relating to the
unpaid tax raised at the hearing, and taken into
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