Scott Roman - Page 1

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                                 T.C. Memo. 2004-20                                   


                               UNITED STATES TAX COURT                                


                             SCOTT ROMAN, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8931-03L.          Filed January 28, 2004.                  

                    P filed a petition for judicial review pursuant to                
               sec. 6330, I.R.C., in response to a determination by R                 
               that levy action is appropriate.                                       
                    Held:  Because there was no abuse of discretion by                
               R in rejecting P’s offer in compromise, R’s                            
               determination to proceed with collection action is                     
               sustained.                                                             
               Kirk T. Karaszkiewicz, for petitioner.                                 
               Jack T. Anagnostis, for respondent.