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determining the present value of the Bergevins’ future
ability to pay. This was done in accordance with IRM
5.8.5.5.
During the course of the negotiations through exchange of
documents and meetings between petitioners’ counsel and the
settlement officer, other issues were discussed. The parties
disagreed as to the effect of a decision entered February 9,
2005, in an abatement action brought by petitioners in this
Court. The decision provided that, with respect to the tax years
1984, 1985, and 1986, petitioners are not entitled to an
abatement of interest under section 6404.
In the notices of determination sent March 3, 2006, the
offer-in-compromise was rejected as follows:
Offers of Collection Alternatives
We considered your offer of $20,652 dated September 27,
2005 and were not able to accept the offer under
existing policies and procedures. * * * [Settlement
Officer Dale Veer] previously provided you with the
details of how this determination was made.
You were given the opportunity to amend your offer to
an amount not less than the current balance owed for
years 1981, 1982, 1983, 1984, 1985 and 1986. You were
also offered the opportunity to either pay the
1981-1986 balances in full or present an alternative
proposal to the offer in compromise. You neglected all
such opportunities.
Discussion
Petitioners invoke our jurisdiction under section 6330(d) to
review the notices of determination sent to them with respect to
the proposed levies on their property. Petitioners contend that
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