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petitioner’s residence; (2) verification of petitioner’s and his
family’s health problems; and (3) the trust documents and
beneficiary schedules for the trusts referenced in petitioner’s
letter. The settlement officer requested this additional
information by October 21, 2004, and informed petitioner that she
would be making her determination at that time. Petitioner
failed to provide any of the requested documentation.
On November 23, 2004, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 for 1987, 1990, 1991, 1997, 1998, 2000, and 2001 (the
determination). The determination concluded that petitioner was
not entitled to challenge his tax liabilities for 1987, 1990, and
1991, as those liabilities had been litigated in the Tax Court.
In her determination, the settlement officer also concluded that
petitioner did not qualify for an offer-in-compromise on grounds
of doubt as to liability because, as just noted, petitioner was
precluded from challenging his 1987, 1990, and 1991 liabilities.
The settlement officer concluded that petitioner did not qualify
for an offer-in-compromise on the basis of doubt as to
collectibility because, after taking into consideration
petitioner’s equity in his residence, petitioner had the means to
fully pay the liabilities.5 Finally, she concluded that because
5 The settlement officer determined that petitioner had
$192,892 of equity in his residence, on the basis of a “forced
(continued...)
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