Judy Hedrick Blosser - Page 9

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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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