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taxpayer who is seeking complete relief from her undisputed tax
liability than when considering a taxpayer who is offering to pay
part of her tax liability, particularly when the procedural
prerequisites are essentially the same in both situations, and we
agree with respondent to that extent. However, this policy does
not excuse the Appeals Office for disregarding a taxpayer’s
attempts to provide current financial information.
Petitioner argues that even if following its established
policies would have shielded the Appeals Office, it still abused
its discretion in denying her CNC status because she provided the
requested information. In particular, petitioner argues that the
Appeals Office erred (1) by claiming that she had not provided
current financial information despite the facts that she had
provided the Appeals Office with a CIS before the hearing and
further explained the changes in her financial situation during
the hearing, and (2) by refusing to consider her statement that
she was incarcerated from 1999 to 2003 as verification of her
assertion that she earned no income, and therefore had no filing
obligation, for those years, or by failing to ask for additional
verification.
Respondent argues that our review is limited to the
administrative record, and there is nothing in the administrative
record indicating that the Appeals Office abused its discretion.
Indeed, there is little that petitioner offers for us to consider
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Last modified: November 10, 2007