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B were submitted the previous year, and no revised forms were
provided.
Mr. Skidmore again documented his consideration of and
concerns with the information provided in extensive notes. He
noted the uncorroborated or unexplained nature of much of what
was supplied, an inability to reconcile various claimed figures
with the documentation, the high cashflow through and commingling
between bank accounts, the apparent failure to make lifestyle
changes to reduce expenses since requesting a year to do so in
November of 2003, and the seemingly continued problems with
filing and payment requirements. These concerns were discussed
at the ensuing hearing conducted on June 22, 2004.
On July 13, 2004, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was issued to
petitioners with respect to 2001 and 2002. The notice summarized
the determination: “The only issue you raised for consideration
was that you be found to be currently not collectible. The
financial information you provided did not establish that. There
were no procedural errors found, neither was it found that a levy
would be overly intrusive.” Petitioners’ petition challenging
this notice, having been timely mailed, was filed on August 16,
2004, at which time they continued to reside in Denver, Colorado.
Each petition raised a number of largely identical
assignments of error, disputing the conclusions in the
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