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submitted a Form 656, Offer In Compromise (OIC). The Appeals
officer notified petitioner and his representative that
additional information was required for approval of an OIC, but
petitioner and his representative continued to fail to provide
it.
On March 9, 2004, respondent issued to petitioner both a
Decision Letter Concerning Equivalent Hearing Under Section 6320
and/or 6330 (Decision Letter) with respect to the proposed levy,
and the Notice Of Determination with respect to the NFTL, both of
which upheld respondent’s collection actions.
Petitioner filed his petition in this case as a result of
the Appeals Office approval of respondent’s collection actions.
Attached to the petition is a copy of the Decision Letter and a
copy of the Notice of Determination concerning 1998. Petitioner
objects to respondent’s filing of the NFTL, in paragraph 4 of the
petition, because he has proposed an “offer and compromise” as an
alternative to the “levy”.
On October 15, 2004, a Notice Setting Case For Trial was
issued, and this case was set for trial in January of 2005. On
December 6, 2004, respondent filed a motion for continuance of
trial. Respondent alleged in the motion that petitioner had
informed respondent on December 2, 2004, that petitioner had been
unaware that his OIC was incomplete. Respondent further alleged
that petitioner had offered to file the necessary information for
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