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2003, notice does not mention currently not collectible status.
However, both notices discuss collection alternatives and
highlight specific reasons why these were rejected. Although the
November 25, 2003, notice does not use the words “currently not
collectible status”, it enumerates particular problems with
respect to petitioners’ ability to qualify for “an Offer in
Compromise or other collection alternative”, and the grounds
listed are patently relevant to evaluation of currently not
collectible status. In point of fact, the majority of
petitioners’ complaints about the notices would seem to relate
more to the possibility of an abuse of discretion, and hence will
be dealt with infra, than to the legal sufficiency of the
documents.
The Court concludes that both the administrative record and
the notices of determination are sufficient to support judicial
review.4
4 We note that we do not decide or reconsider whether we are
limited to the administrative record in conducting our review, as
that is not at issue in these cases.
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