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new data, her point, in this particular context, is not well
taken.
As a general matter, taxpayers are usually responsible for
establishing their positions before the IRS. Second, on a more
specific and practical level, petitioner, despite being
represented by counsel, apparently never alerted the Appeals
officer of any relevant change in circumstances. Furthermore,
the types of items reported on the Form 12510 were not inherently
of a nature to raise a suspicion of dramatic change over the
course of the ensuing period. The only likely difference hinted
at on the face of the Form 12510 would have been a reduction in
income, as petitioner appended a comment that she might be unable
to continue to sustain multiple jobs. However, third-party
payers reported to the IRS even higher wages of $87,925 for the
completed taxable year of 2003 (the most recent year for which
records would have been available during at least the majority of
the time petitioner’s case was before Mr. Pearce). This fact was
noted by the Appeals officer in his recommendations. Third-party
payers similarly reported still higher wages to petitioner of
$90,974 for 2004. In this scenario, the Court, despite its
admiration for petitioner’s efforts to help herself, is
unconvinced that petitioner may abdicate all responsibility for
raising some issue of pertinent change or, conversely, that the
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