Laura K. Davis, et al. - Page 8

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          accompanied by an attachment, wherein the settlement officer sets           
          forth the analysis leading to his conclusion that the collection            
          actions should be sustained.  The analysis in each attachment is            
          similar, and the following are among the facts, generally similar           
          in each attachment, on which the settlement officer relied:                 
          Petitioner could not challenge the underlying tax liability                 
          because he had received a notice of deficiency.  Petitioner had             
          neither requested release or withdrawal of the NFTL nor shown               
          that he was entitled to release or withdrawal of the NFTL.  No              
          collection alternatives, such as an offer-in-compromise or an               
          installment agreement, were finalized with petitioner because he            
          either did not respond with any alternatives or still believes              
          that he does not owe the liability and that this is a whipsaw               
          case.  Where relevant, petitioner had not provided information              
          necessary for innocent spouse relief for Ms. Davis.  Appeals had            
          verified the assessments of tax.  The requirements of all                   
          applicable laws and administrative procedures had been met.  The            
          proposed collection action balanced the need for efficient                  
          collection with petitioner’s concern that any collection action             
          be no more intrusive than necessary.                                        
               On January 3, 2005, each petitioner timely petitioned for              
          review of the notice received by that petitioner.  Each                     
          petitioner assigned error in substantially the same terms.                  

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