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taxpayer to the appropriateness of the collection
action; it will respond to any offers by the taxpayer
for collection alternatives; and it will address
whether the proposed collection action represents a
balance between the need for the efficient collection
of taxes and the legitimate concern of the taxpayer
that any collection action be no more intrusive than
necessary. The Notice of Determination will also set
forth any agreements that Appeals reached with the
taxpayer, any relief given the taxpayer, and any
actions the taxpayer or the IRS are required to take.
Lastly, the Notice of Determination will advise the
taxpayer of the taxpayer’s right to seek judicial
review within 30 days of the date of the Notice of
Determination. [Sec. 301.6330-1(e)(3), A-E8(i),
Proced. & Admin. Regs.]
The notices of determination precipitating these cases
expressly address verification of legal and procedural
requirements, issues raised, and balancing of efficiency and
intrusion. While petitioners would apparently like to see even
greater detail, the discussions provided as to each of the
foregoing components are sufficient to enable the Court to follow
the Appeals officer’s reasoning and conclusions. Furthermore,
the Court is mindful that a notice of determination, as a single,
relatively succinct document following an often lengthy
administrative process, must necessarily be to some degree
summary in nature.
For example, petitioners direct our attention to the fact
that they offered collection alternatives, including an offer-in-
compromise and currently not collectible status, and argue that
Mr. Skidmore failed adequately to address these issues in the
notices of determination. They emphasize that the November 25,
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