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occurred in person, over the telephone, and via e-mail and
without petitioner’s participation.
Among other communications, the revenue officers in
California and Oregon communicated to the Appeals officer concern
about assets that petitioner may have transferred to a nominee.
Also, the revenue officer in Oregon suggested to the Appeals
officer and to the offer specialist that they should “probe and
inquire if there were any links or money stream to * * *
[petitioner]” relating to a home in Oregon.
On May 27, 2004, the offer specialist recommended that the
Appeals Office reject petitioner’s OIC, explaining that
petitioner had paid insufficient individual estimated taxes and
that the eldercare business had paid insufficient payroll taxes.
The offer specialist also explained that petitioner’s OIC should
be rejected because the outstanding taxes petitioner owed related
to what the offer specialist described as “nominee, transferee,
fraud issues –- case is filled with them as it is the basis of
the assessments.”
On May 26, 2005, the Appeals Office issued a notice of
determination (notice) sustaining the tax lien filed against
petitioner. Attached to the notice was the Appeals officer’s
general statement that petitioner’s OIC was not in the best
interest of the Government because of, among other things,
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