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(which Mr. Burke disclosed to Ms. Boudreau). After the phone
conversation, Mr. Burke faxed a letter to Ms. Boudreau asking
that she reconsider her decision to close petitioner’s case. The
letter contains no new financial information and makes no new
offer. Ms. Boudreau reviewed the letter and the case file and
concluded that her decision to reject the offer should stand.
By Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated May 29, 2003 (the notice of
determination), Ms. Boudreau’s supervisor notified petitioner
that Appeals had sustained respondent’s decision to proceed with
collection of the unpaid tax by levy. An attachment to the
notice of determination explains in some detail the matters
considered at the hearing and the conclusions reached. It
contains, among other things, statements that a review of
petitioner’s administrative file indicated that the statutory and
administrative requirements that needed to be met with respect to
the proposed levy had been satisfied, the offer in compromise was
not a viable collection alternative, and collection by levy was
necessary to provide for the efficient collection of the taxes
despite the potential intrusiveness of enforced collection.
Petitioner timely petitioned this Court for review of the
notice of determination.
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