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offer was returned to petitioners as not processable in the form
submitted. A second offer (we assume corrected) was sent to the
IRS the day after the notices of determination were sent. Since
there was no offer in compromise before Appeals, there was no
abuse of discretion in Appeals’ failing to consider an offer in
compromise. Finally, petitioners can raise no issue here that
they did not raise during their collection due process hearing.
See Magana v. Commissioner, 118 T.C. 488, 493 (2002); secs.
301.6320-1(f)(2), Q&A-F5, and 301.6330-1(f)(2), Q&A-F5, Proced. &
Admin. Regs.
D. Conclusion
Petitioners have failed to show any error in Appeals’
determination to proceed to collect by levy the unpaid
assessments.
IV. Conclusion
As stated, we shall grant the motion.
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011