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offered no explanation of why any losses that were incurred in
1994, 1995, and 1996 would not have been taken into account when
he belatedly filed, in 1997, his return for 1993.
Petitioner has failed to show that the assessed liability
for 1993 is erroneous in any respect. Although he claims
inability to pay the liability, he has neither offered any
collection alternatives nor complied with requirements for an
offer in compromise. See sec. 301.7122-1, Proced. & Admin. Regs.
On the record in this case, the notice of determination that
was sent to petitioner must be sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011