- 6 - 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 onPage: Previous 1 2 3 4 5 6 7 8 9 Next
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