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during the administrative process and could have but did not
raise it.
The settlement officer assigned to petitioners’ case offered
petitioners several opportunities to propose collection
alternatives or to provide other pertinent information. However,
petitioners responded with nothing but frivolous arguments.
Petitioners did not make an offer in compromise, offer to pay
their delinquent taxes under an installment plan, or tell the
settlement officer that petitioner had requested assistance on
hardship grounds from the Taxpayer Advocate Service. Petitioners
did not give the Appeals Office the opportunity to conduct an
independent review of their financial circumstances. Other than
submitting a copy of the Countrywide complaint, petitioners
offered the Court no support for their hardship claim.
Petitioners are in their late 50s and have both been
gainfully employed in recent years. There is no indication (a)
how petitioners used the funds that should have been withheld
from petitioner’s wages, (b) that petitioners have dependents or
unusual financial demands, or (c) that the proposed collection
actions would cause petitioners to be unable to pay their
reasonable basic living expenses. See sec. 301.6343-1, Proced. &
Admin. Regs.
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Last modified: May 25, 2011