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Your lack of current tax compliance defeated the
finding of collection alternatives, and the financial
information you provided indicated an ability to make
significant payments on the outstanding tax, if not
fully pay it over the next few years. You did not
evidence that a levy would be overly intrusive. You
did not show reasonable cause for penalty abatement.
Petitioners filed a petition with this Court challenging the
November 25, 2003, determination on December 22, 2003, at which
time they resided in Denver, Colorado.
In the meantime, on October 20, 2003, the IRS had issued to
petitioners a Final Notice - Notice of Intent To Levy and Notice
of Your Right to a Hearing with respect to 2001 and 2002.
Petitioners timely submitted a Form 12153, received by the IRS on
November 19, 2003, in response to the notice of intent to levy.
An attachment explaining their disagreement essentially reprised
(almost verbatim) the points made in their November 17, 2003,
letter to Mr. Skidmore and focused on a request for placement of
their accounts in currently not collectible status.
This case was again assigned to Mr. Skidmore. By a letter
dated April 8, 2004, Mr. Skidmore offered a hearing to be held on
April 27, 2004. On April 20, 2004, petitioners’ representative
called and requested that Mr. Skidmore recuse himself and have a
different Appeals officer handle the 2001 and 2002 case on
account of Mr. Skidmore’s work on prior years. Upon review of
3(...continued)
second copy.
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