Louis A. and Christine Cox - Page 34

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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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