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apart from the information contained in the administrative file.
Nevertheless, this case is a good example of the problems created
by the lack of a transcript or actual record of the discussions
between the taxpayer and the settlement officer. The only record
of the April 6, 2006, telephone conversation between petitioner
and the settlement officer is the entry made by the settlement
officer in her log for this case. This telephone conversation
was the only “hearing” that petitioner received, and the
settlement officer’s entry is very abbreviated. We are forced to
make certain inferences from the information that is known.
According to the settlement officer’s entry, petitioner
submitted a CIS when she requested a collection hearing, and the
settlement officer knew this. Petitioner told the settlement
officer that she lost her full-time job and gained a part-time
job after she had submitted the CIS. Petitioner explained that
she was unable to provide a new CIS because her family had
recently experienced a tragedy. She also explained that she did
not file Federal tax returns for 1999 to 2003 because she was
incarcerated during those years. After hearing this information,
the settlement officer told petitioner that respondent would be
sending her a notice of determination. There is no indication in
the administrative record that the settlement officer discussed
the particulars of the changes in petitioner’s financial
information from the time she completed the CIS in September
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