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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.
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