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credited against petitioner’s 1987 liability. The record
contains no credible evidence to suggest that these installment
payments were improperly credited or that petitioner made
additional payments that were not credited.
3. Collection Alternatives
Petitioner has not expressly assigned error to the
settlement officer’s rejection of his offer-in-compromise. To
the extent that the petition might be construed to raise such a
claim by implication, we hold that the settlement officer did not
abuse her discretion in rejecting petitioner’s offer-in-
compromise, inasmuch as petitioner was not entitled to challenge
his underlying tax liabilities for 1987, 1990, and 1991, see sec.
301.7122-1(b)(1), Proced. & Admin. Regs.; failed to timely comply
with the settlement officer’s requests for complete current
financial information to establish doubt as to collectibility or
economic hardship, see sec. 301.7122-1(b)(2) and (3), Proced. &
Admin. Regs.; failed to submit a copy of his 2003 tax return to
show the settlement officer that he was in current compliance
with filing requirements, see Rodriguez v. Commissioner, T.C.
Memo. 2003-153; and altered the standard terms of Form 656 so as
to delete the statement that he was signing the form under
penalties of perjury, see Rev. Proc. 2003-71, sec. 4.01, 2003-2
C.B. 517 (Form 656 must be signed under penalty of perjury and
none of its standard terms may be stricken or altered).
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