- 19 - Throughout the CDP hearing, petitioner clearly expressed an interest in a collection alternative such as an installment agreement. The Appeals officer testified that he first had to ensure that petitioner was in current compliance with petitioner’s tax obligations before he could consider a collection alternative such as an offer-in-compromise or an installment agreement. He further required petitioner to submit Form 433-A in order to consider collection alternatives. Pursuant to the Appeals officer’s directives, petitioner submitted a completed Form 433-A and became compliant with his tax obligations by October 15, 2004. Thereafter, the Appeals officer determined that there was an income discrepancy of $175 between information reported on petitioner’s 2003 return and Form 433-A. To clarify this discrepancy, the Appeals officer requested petitioner to submit additional financial information, such as business receipt and expense information, by November 4, 2004. At a time not disclosed in the record, petitioner submitted several documents, including bank and expense statements, business and rent invoices, and utility bills. The Appeals officer closed the case on November 16, 2004. The Appeals officer determined that he could not consider an installment agreement largely on the basis that he did not have the required financial information to reconcile the $175 incomePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011