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final notice to petitioners in respect of their outstanding
liability for 2002, which, at that time, was approximately $1,407
(without regard to statutory accruals of interest and penalty).
Administrative Developments
Petitioners timely filed with respondent a Form 12153,
Request for a Collection Due Process Hearing. In the Form 12153,
petitioners focused only on the existence or amount of their
underlying liability.
By letter dated August 16, 2006, respondent’s settlement
officer advised petitioners that, inter alia:
For me to consider alternative collection methods such
as an installment agreement or offer in compromise, you
must provide any items listed below. In addition, you
must have filed all federal tax returns required to be
filed.
The “items listed below” included a completed Collection
Information Statement (Form 433-A for individuals and/or Form
433-B for businesses) and signed income tax returns for 2003,
2004, and 2005. Regarding the latter, the settlement officer
stated that “Our records indicate they have not been filed”.
The settlement officer subsequently conducted a telephonic
conference with Mrs. Manousos.
Petitioners never submitted a Collection Information
Statement or proposed a specific collection alternative, nor did
petitioners file all of the requested returns during the time
that their case was pending before respondent’s Appeals Office.
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Last modified: November 10, 2007