William G. Wells - Page 8

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            records within this period of time, and there is no evidence that                           
            petitioner was unable to assist his attorney.                                               
                  Petitioner did not submit an offer-in-compromise or any                               
            financial information to respondent.  Respondent gave petitioner                            
            a reasonable amount of time to submit information about his                                 
            financial condition.6  We conclude that respondent’s                                        
            determination was not an abuse of discretion.7                                              
                  Petitioner has failed to raise a spousal defense or make a                            
            valid challenge to the appropriateness of respondent’s intended                             
            collection action.  These issues are now deemed conceded.  Rule                             
            331(b)(4).                                                                                  
                  In reaching all of our holdings herein, we have considered                            
            all arguments made by the parties, and to the extent not                                    
            mentioned above, we find them to be irrelevant or without merit.                            
                  To reflect the foregoing,                                                             
                                                             Decision will be entered                   
                                                       for respondent.                                  






                  6  Additionally, petitioner provided no evidence of his                               
            financial condition at trial that could allow us to conclude that                           
            a remand of this case would prove to be helpful.                                            
                  7  We note that respondent also considered the fact that                              
            petitioner had defaulted on a prior installment agreement as an                             
            additional reason to proceed with collection.                                               





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