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cause for abatement of the additions to tax. The settlement
officer ultimately recommended rejection of petitioner’s offer-
in-compromise, and on March 15, 2006, respondent’s Appeals Office
issued notices of determination sustaining the levy actions for
the tax years in issue.
Petitioner timely filed his petitions, in which he seeks
review of respondent’s determinations. Petitioner contends that
respondent acted impermissibly: (1) In denying petitioner’s
requests for abatement of additions to tax, (2) in rejecting
petitioner’s offer-in-compromise, and (3) in sustaining the
proposed levy actions.
Discussion
The parties are not at odds regarding the technical
provisions of section 6330. Further, petitioner does not claim
that respondent failed to satisfy any of the mechanical or
procedural obligations contemplated by that statute. Nor does
petitioner contest the propriety of the assessments of tax as a
procedural matter. Consequently, we immediately turn our
attention to petitioner’s complaints and begin with his first
contention that respondent acted impermissibly in denying
petitioner’s requests for abatement of additions to tax due to
reasonable cause. We construe petitioner’s position in this
regard to be that he should not be held liable for the additions
to tax.
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