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which she did in July 2003 and February 2004. Petitioner’s
refusal to provide the requested information was grounds for
returning his OIC. Accordingly, petitioner has not shown that
compromising his tax liabilities would promote effective tax
administration.
Applicable Law and Administrative Procedure
Petitioner’s final argument is that respondent failed to
comply with section 6330(c). This section provides that the
officer conducting the administrative hearing must verify that
the requirements of applicable law and administrative procedure
have been met. For example, the hearing officer must verify that
the taxpayer was properly issued a notice of Federal tax lien,
which must include the amount of unpaid tax, the taxpayer’s right
to request an administrative hearing, the administrative appeals
available to the taxpayer, and the procedures relating to the
release of liens. Sec. 6320(a)(1)-(3); see also Anderson v.
Commissioner, T.C. Memo. 2003-112.
Petitioner’s sole contention with respect to section 6330(c)
is that the Internal Revenue Manual (IRM) prohibits the filing a
notice of Federal tax lien if the taxpayer’s unpaid balance of
assessment is under $5,000. The total amount reflected on the
notice of Federal tax lien that respondent filed against
petitioner was $4,619.60. Thus, petitioner argues, the
settlement officer erred in determining that petitioner’s “unpaid
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