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such matters. See Murphy v. Commissioner, 125 T.C. 301, 320
(2005), affd. 469 F.3d 27 (1st Cir. 2006). Whether we agree or
disagree on the point is unimportant. It can hardly be said the
settlement officer’s conclusion was in any way arbitrary,
capricious, or without sound basis in fact. Respondent’s refusal
to accept the installment agreement proposed by petitioner during
the section 6320 administrative hearing was not an abuse of
discretion.
At the section 6320(c) administrative hearing, petitioner
challenged the appropriateness of respondent’s proposed
collection activity and offered a collection alternative. See
sec. 6330(c)(2)(A)(ii) and (iii). The record establishes that
the settlement officer took into account petitioner’s challenge,
considered petitioner’s collection alternative, and otherwise
proceeded in the manner contemplated by sections 6320 and 6330.
Petitioner has not called our attention to any specific
provisions of the relevant statutes, regulations, or provisions
of the Internal Revenue Manual that the settlement officer has
violated or failed to take into account.
Considering all of the facts and circumstances, we are
satisfied that respondent’s determination that the NFTL is an
appropriate collection action with respect to petitioner’s
outstanding tax liabilities is supported in law and in fact. It
follows that the determination is not an abuse of discretion, see
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