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likely be able to pay his tax liability in full, Ms. Merriam
asked Ms. Lee to consider the effective tax administration offer-
in-compromise. The letter set out in detail petitioner’s
position regarding an effective tax administration offer-in-
compromise, but a Form 656 was not enclosed.
On March 30, 2004, respondent sent petitioner a notice of
determination sustaining the proposed collection action.
Respondent stated that “We are unable to determine whether or not
an Offer in Compromise is the appropriate resolution because you
failed to provide the financial information necessary to make a
collection determination.”
In response to the notice of determination, petitioner filed
his petition with this Court on May 5, 2004. Petitioner argued
that respondent erred by: (1) Determining that petitioner did
not qualify for an effective tax administration offer-in-
compromise; and (2) failing to allow petitioner sufficient time
to provide additional information.7
This case was initially calendared for trial beginning
January 24, 2005. However, the parties’ joint motions for
continuance and remand were granted at calendar call. The case
was remanded to respondent’s Appeals Office to give petitioner an
7 Petitioner also alleged that respondent erred by not
finding that there was doubt as to collectibility. However,
petitioner did not present information to substantiate this claim
and does not argue it on brief. We conclude that petitioner has
abandoned this argument.
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