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T.C. 19, 23 (1999). Because petitioner does not dispute her
underlying tax liability, we apply the abuse of discretion
standard.
Under section 6330(c)(3), in making a determination the
Appeals Office must (1) verify that the requirements of
applicable law and administrative procedures have been met, (2)
consider the issues the taxpayer raised at the hearing, including
collection alternatives, and (3) determine whether any proposed
collection action balances the need for the efficient collection
of taxes with the legitimate concern of the person that any
collection be no more intrusive than necessary. Petitioner
argues only that the Appeals Office abused its discretion by
failing to consider the collection alternative she proposed
during the telephone hearing.
The Internal Revenue Manual states that settlement officers
may not consider collection alternatives unless the taxpayer has
provided adequate financial information, such as the filing of a
current CIS, and has filed all required tax returns. See 2
Administration, Internal Revenue Manual (CCH), sec.
5.16.1.2.9(1), at 17,810; sec. 5.15.1.1, at 17,653. Petitioner
does not object to this policy, and we have found it to be
reasonable. See Estate of Atkinson v. Commissioner, T.C. Memo.
2007-89. It is also the policy of the Appeals Office to request
a new CIS if the taxpayer’s financial condition changes after the
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