Juanita and Emmanuel Kendricks - Page 8

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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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