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Petitioner does not deny the facts relating to the late
filing of his Federal income tax returns and his history of
noncompliance with his Federal income tax filing and payment
obligations.
On September 20, 2001, petitioner filed his petition herein.
Discussion
At no point herein has petitioner challenged the amount of
his underlying Federal income tax liabilities for the years in
issue.
Where the issue of the underlying tax liability is not
before the Court in connection with a collection hearing, the
Court reviews respondent’s Appeals Office determination only for
abuse of discretion. Magana v. Commissioner, 118 T.C. 488, 493
(2002); Sego v. Commissioner, 114 T.C. 604 (2000); Goza v.
Commissioner, 114 T.C. 176 (2000).
Respondent argues that summary judgment is appropriate on
the ground that the undisputed facts establish that petitioner
was not in current compliance with his Federal income tax
liabilities, and that respondent’s determination to reject
petitioner’s offer in compromise did not constitute an abuse of
discretion. We agree.
Petitioner’s history of noncompliance, the late filing of
his Federal income tax return for 2000, and the delinquency on
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