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The record here does not support a finding that there was an
abuse of discretion by respondent's Appeals Office in denying
relief to petitioner. Petitioner's claim that he had an
agreement for an installment payment method with an abatement by
respondent of a portion of the deficiency, interest, and
penalties was not established. Moreover, the Appeals Office
considered that contention and determined there was no basis for
petitioner's claim. Nothing was presented by petitioner to the
Court that would establish an abuse of discretion by the Appeals
Office in reaching this conclusion. Petitioner was offered two
opportunities by the Appeals Office to submit proposals for
alternative means of collection by respondent. Petitioner did
not submit any alternative collection methods for consideration
by respondent. Again, there was no abuse of discretion by the
Appeals Office in its determination that the levy should proceed.
Accordingly, the notice of determination by the Appeals Office
will be sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011