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he has been unable to get the subsequent years returns
prepared. During the CDP proceedings, Mr. Westcott was
able to get his 1999 return filed and the carry back
reduced the balance due by about $20,000.00, but there
is still about $29,000.00 due. I have received the
names and telephone numbers of two low income tax
preparation services from the Taxpayer Advocate and
have provided those to Mr. Westcott with the advice
that he get his 2000 and 2001 returns filed and I would
help him file an Offer in Compromise, doubt as to
liability. But because these returns are still out-
standing, I cannot enter into any type of alternate
collection action.
III. Balancing Efficient Collection And Intrusiveness.
Mr. Westcott cannot enter into any type of alternate
collection action because he is not in compliance with
filing of his returns; therefore, the proposed levy is
the only method of efficient collection. [Reproduced
literally.]
In June 2005, after petitioner filed a petition with the
Court in response to the notice of determination that the Appeals
Office issued with respect to his taxable year 1998, petitioner
filed Form 1040 for his taxable year 2000 (2000 return). In
petitioner’s 2000 return, petitioner claimed a business loss of
$36,514 from Schedule C and negative total income and negative
adjusted gross income of $17,299. On dates not disclosed by the
record after March 7, 2003, petitioner filed tax returns for his
respective taxable years 2001 through 2004.7
Petitioner received general assistance from the Internal
Revenue Service (IRS) on how to navigate the processes relating
7The record does not disclose the contents of the respective
tax returns that petitioner filed for his taxable years 2001
through 2005.
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