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offer was temporarily put on hold “pending a review of the ISO
rulings by National Office.” Petitioner was later advised by
respondent’s offer specialist that “the Effective Tax
Administration offer is not feasible as it is used [only] when
the net realizable equity [in the taxpayer’s assets] exceeds the
tax amount”, which was not the case here.
On May 1, 2003, petitioner submitted an amended offer-in-
compromise (amended OIC), which contained only doubt as to
collectibility and effective tax administration (ETA) as reasons
for the offer, and again contained no dollar amount, which
respondent treated as $1, and again rejected. Petitioner then
filed a protest, and respondent’s settlement officer in general
appeals programs sustained the rejection of the amended OIC.
On May 20, 2004, respondent mailed to petitioner a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing, in response to which petitioner requested a hearing
(Appeals hearing). In the request, petitioner asserted that
respondent’s rejection of petitioner’s OIC was an abuse of
discretion.
On September 8, 2004, respondent advised petitioner that the
Appeals Office had sustained respondent’s Final Notice - Notice
of Intent to Levy and Notice of Your Right to a Hearing for the
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