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PETER P. BALTIC AND KAREN R. BALTIC, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

Docket No. 2826-06L. Filed December 27, 2007.

Bs received a notice of deficiency but filed no petition in this Court. R assessed the tax reported and then sent Bs CDP notices that he had filed notices of federal tax hen and intended to collect the unpaid tax by levy. Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability. R's officer who conducted the hearing issued a notice of determination sustaining the filing of the lien and postponing the levy but refused to consider Bs' proposed offer herself. Held, R committed no abuse of discretion in issuing the notice of determination, because sec. 6330(c), I.R.C., bars taxpayers who've received a ...

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