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offered. 2 Administration, Internal Revenue Manual (CCH), sec.
5.8.1.3.5, at 16,256.
Mr. Kane properly applied these procedures to arrive at the
proposal offered to petitioners. Petitioners’ challenges to the
appropriateness of the collection action were based upon Mr.
Galvin’s poor health and the possibility that he would be unable
to continue to work. Mr. Kane took these factors, as well as the
age of the tax liabilities, into consideration in making
respondent’s proposal.
Petitioners have not presented any evidence or persuasive
arguments to convince us that respondent abused his discretion.
See Black v. Commissioner, T.C. Memo. 2002-307. As a result, we
hold the issuance of the notice of determination was not an abuse
of respondent’s discretion and respondent may proceed with
collection.
In reaching our holding herein, we have considered all
arguments made, and to the extent not mentioned above, we
conclude them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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