Judy Hedrick Blosser - Page 8

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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            
               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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