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discrepancy between Form 433-A and petitioner’s 2003 return.8
The record, however, does not reveal the basis for this finding.
At trial, the Appeals officer could not identify what specific
document he was seeking to reconcile the $175 discrepancy, but he
acknowledged that petitioner submitted several personal and
business financial documents. The Appeals officer testified, in
relevant part, that he was
trying to seek current business receipt information and
current business expense information to determine the
actual net income that he [petitioner] was receiving so
that I could determine, you know, compare it with the
expenses, actually verify the expenses and then verify
the current income to determine if there could be an
installment agreement and what that amount would be, if
there could be.
We find the $175 income discrepancy to be de minimis in
amount. Furthermore, we are not persuaded that the Appeals
officer may not have received the “financial information
requested” that was necessary to reconcile the $175 amount,
especially in light of the fact that at trial he was unable to
specify what document he was seeking. At the very least, the
record demonstrates that, notwithstanding the de minimis amount,
petitioner had complied with the Appeals officer’s directives
sufficient for the Appeals officer to make a financial analysis
8 We note, in contrast, that on July 29, 2004, the Appeals
officer indicated in his notes that Form 433-A showed that
petitioner had “very little ability to make installment
payments.”
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