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On May 24, 2005, a settlement officer with the Appeals
Office (settlement officer) sent a letter (settlement officer’s
May 24, 2005 letter) to petitioner with respect to petitioner’s
Form 12153. In that letter, the settlement officer stated in
pertinent part:
I have received your Collection Due Process hearing
request. The objective of a Collection Due process
hearing is to determine whether an acceptance alterna-
tive to the levy/lien exists, while balancing the
Government’s need to efficiently collect this tax
liability. Options available to you for resolution of
your lien/levy issue may include the following:
• Full payment
• Installment agreement
• Offer in Compromise
• Surety bond
On your hearing request you indicated your offer was
rejected because of non-compliance. A check of our
records indicated you had an outstanding balance on
your tax return for period ending 12/31/2003. The
outstanding balance was paid after the offer was re-
jected. You cannot accumulate new liabilities. Our
records also indicate you have an outstanding liability
for period ending 12/31/2004. I have attached a tran-
script for period ending 12/31/2003.[19] If you wish to
submit an offer, you must start the process again.
If you feel that one of the above resolutions are
possible, please respond back with your proposal by no
later than June 15th 2005. If your proposal is any-
thing other than full payment, then I will need you to
complete and return the enclosed Forms 433-A & B. If
you do not own a business, then please disregard the
19The record does not contain the “transcript for period
ending 12/31/2003” referred to in the settlement officer’s May
24, 2005 letter.
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Last modified: March 27, 2008