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adequate time to participate in and complete a proper hearing.
Petitioners’ claim that they did not have sufficient time to
retrieve IRS documentation fails to raise any relevant issue. A
settlement officer is not required to produce any documents at a
section 6330 hearing. Petitioner Ines M. Gillespie had failed in
docket Nos. 3405-05L and 3490-05L to raise an innocent spouse
claim either on the Form 12153 or at any time during the
administrative process, and, for that reason, she could not raise
that claim in these proceedings. There is no merit to
petitioners’ claim that any assessment is untimely. Petitioners’
claim that the settlement officer was biased against them because
of their use of the trust system is frivolous and
unsubstantiated. No other error assigned by petitioners raises
any justiciable issue or shows any abuse of discretion by the
settlement officer.
Petitioners’ Objections
On February 6, 2006, petitioners all filed objections to the
motions for summary judgment. None of petitioners disputed that
they failed to present collection alternatives. In each case,
they argued that the settlement officer had not given them
adequate time to make their case and they had required additional
information to prepare collection alternatives and to resolve
other issues relating to the years at issue. In docket No. 3405-
05L, petitioners argued that the assessment of tax for 1997 was
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