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the poor economy, his lack of knowledge of the tax law, and his
fear of losing his job. Petitioner requested guidance on
obtaining an abatement of interest and relief from the additions
to tax. By letter dated August 9, 2005, the settlement officer
detailed the requirements for a request for relief from additions
to tax,7 informed petitioner that respondent was required by
statute to assess interest in his case and that the interest
could not be abated, and referred petitioner to the Internal
Revenue Manual for further information. By letter dated August
29, 2005, petitioner once again requested the abatement of
interest and relief from the additions to tax because of the
downturn in the economy and his lack of knowledge regarding the
tax implications of employee stock options.
On November 18, 2005, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination). The notice
of determination stated that respondent had verified that all
statutory and administrative requirements had been met, that
respondent had addressed all of petitioner’s arguments raised at
the face-to-face hearing, and that respondent had determined that
the lien appropriately balanced the Government’s need for the
efficient collection of taxes and petitioner’s concern that the
7The settlement officer used the term “penalties” in the
letter, but she was referring to additions to tax.
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