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We note that even if petitioner did mail the Form 433-F on
that date, the settlement officer requested a Form 433-A. As
described above, the Form 433-A requires the taxpayer to provide
substantially more financial information, such as pay stubs and
bank records, than does the Form 433-F. Petitioner does not
contend that she mailed these documents to the settlement
officer. Thus, petitioner did not provide complete financial
information. See Roman v. Commissioner, supra. Moreover, the
Form 433-F that petitioner provided appears incomplete in several
respects. For example, petitioner lists monthly income of $1,500
and monthly expenses of $5,056. The Form 433-F gives no
indication how petitioner covered the shortfall between the
reported income and expenses. Petitioner listed no assets other
than $100 in a checking account. The only debt listed is $450 of
credit card debt. Petitioner also failed to indicate she was a
physician or include a business address as requested on the Form
433-F.
On the basis of our review of the record, we conclude that
respondent satisfied the requirements of section 6330(c) and did
not abuse his discretion in refusing to consider collection
alternatives and sustaining the proposed levy against petitioner.
Respondent’s determination therefore is sustained.
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Last modified: May 25, 2011