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Reconsideration and subsequent orders of the Tax
Court.[6]
2. At this time, enforced collection activity is
unnecessary and unwarranted. If the assessment
against Taxpayers is ultimately sustained, Mr.
Gazi will cooperate with the Service to consider
reasonable collection alternatives, including, but
not limited to, an installment agreement or an
Offer in Compromise.
Conclusion:
Based on the foregoing, Mohammed A. Gazi and the
Estate of Raees I. Gazi request a collection due pro-
cess hearing. * * * [Reproduced literally.]
On October 31, 2005, while their motion for reconsideration
of the July 28, 2005 Opinion was pending before the Court, Mr.
Gazi and Ms. Gazi’s estate filed a notice of appeal with the
United States Court of Appeals for the Eleventh Circuit (Court of
Appeals for the Eleventh Circuit).
On March 24, 2006, the settlement officer with the Appeals
Office assigned to consider Mr. Gazi’s Form 12153 (settlement
officer) made the following pertinent entries in his “Case
Activity Records”:
Reviewed file. * * * A review of the file shows the
assessments are all agreed audits that have been sus-
tained by the court ruling. The POA [Ms. Ciraolo] has
attempted to delay collection by several actions. It
was previously agreed she would post a bond but did
not. She had a CAP hearing for the FTL under the same
6The only Order attached to the copy of Mr. Gazi’s Form
12153 that is in the record in the instant case is an Order in
the Gazis’ Tax Court case dated Sept. 8, 2005, in which the Court
ordered the Commissioner to file by Sept. 22, 2005, a response to
the motion for reconsideration of the July 28, 2005 Opinion.
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