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the information required in order to consider an alternative
collection action.
Throughout the proceeding, petitioner’s conduct demonstrates
propensity to cause delay in collecting his outstanding tax
liabilities. We sustain respondent’s determination regarding the
proposed levy as a permissible exercise of discretion. We note
as to the allegations set forth in the petition that petitioner
did receive a hearing under section 6330, that petitioner was
given an opportunity to participate in the proceeding relating to
an offer in compromise, and that petitioner’s unsupported
allegations raise no triable issue of fact concerning “punitive
conduct” by the IRS personnel.
Regarding the petitioner’s request to refer this case to a
different forum, we observe that this Court has jurisdiction over
the appeal of the administrative determinations where the
underlying tax liability concerns unpaid income taxes, as opposed
to certain other taxes. See, e.g., Goza v. Commissioner, supra
at 182. We decline to grant the petitioner’s request.
We have considered all arguments raised by the parties and
have found those arguments not discussed herein to be irrelevant
and/or without merit. Accordingly,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011