J. Jean Moore - Page 6

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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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