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document such analysis in a manner or form that would enable
objective verification thereof by an Appeals officer in some
future proceeding. Moreover, the structure of section 6330 as
enacted is such that the Appeals officer is expressly instructed
to consider collection alternatives, presumably de novo, and
courts are granted jurisdiction to review the Appeals officer’s
exercise of discretion, not that of an earlier revenue officer.
Petitioners’ approach does not harmonize with the language of the
statute. The Court concludes that the verification requirement
was met on the facts of these cases.
Petitioners also advance complaints with respect to the
Appeals officer’s consideration of issues they raised in
connection with the hearing. These complaints, apparently
seeking to show contravention of section 6330(c)(3)(B), center on
the interrelated categories of compliance and collection
alternatives. Regarding compliance, neither party disputes that
current compliance with tax laws is generally considered a
prerequisite, under established IRS policy, of eligibility for
collection alternatives. See, e.g., Rodriguez v. Commissioner,
T.C. Memo. 2003-153; Londono v. Commissioner, T.C. Memo. 2003-99;
Tabak v. Commissioner, T.C. Memo. 2003-4. Nor is there any
material disagreement that petitioners’ compliance record for the
years in issue was, in petitioners’ words, “not exemplary” or, in
respondent’s characterization, “abysmal”. Petitioners argue,
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