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v. Commissioner, supra. Nevertheless, we address petitioners’
arguments.
1. Discussion of Special Circumstances in the Notice of
Determination
Petitioners argue that Ms. Cochran failed “to follow proper
procedure by discussing Petitioners’ special circumstances, what
equity was considered in relation to their special circumstances,
and how the special circumstances affected her determination of
their ability to pay.” Petitioners infer that, because the
special circumstances were not discussed in detail in the notice
of determination, Ms. Cochran failed to adequately take their
circumstances into consideration.
We do not believe that Appeals must specifically list in the
notice of determination every single fact that it considered in
arriving at the determination. See Barnes v. Commissioner,
supra. This is especially true in a case such as this, where
petitioners provided Ms. Cochran with multiple letters and
hundreds of pages of exhibits. As discussed below, Ms. Cochran
considered all of the arguments and information presented to her.
Given the amount of information, it would be unreasonable to put
the burden on Ms. Cochran to specifically address in the notice
of determination every single asserted fact, circumstance, and
argument presented. The fact that all of the information was not
specifically addressed in the notice of determination was not an
abuse of discretion.
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