- 31 - envelope. On September 16, 2003, Appeals Officer Kaplan verbally reminded Attorney Burke that he had not received the information requested on July 2, 2003. Finally, on October 27, 2003, Appeals Officer Kaplan informed Mr. Burke that information previously requested had not been received and that the Appeals Office would issue a determination based on information already in its possession unless Mr. Burke submitted the information immediately. The record clearly demonstrates not only that petitioner failed to submit a viable offer-in-compromise for the consideration of respondent’s Appeals officer, but that Settlement Officer O’Shea and Appeals Officer Kaplan repeatedly provided petitioner with the opportunity to submit an offer-in- compromise for consideration. Based on the administrative record, we hold that Settlement Officer O’Shea and Appeals Officer Kaplan balanced the need for the efficient collection of taxes with concern that the collection action be no more intrusive than necessary. IV. Issues With Respect to the Supplemental Notice of Determination We now address the issues raised by petitioner with respect to the supplemental notice of determination.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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