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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.
Petitions
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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