T.C. Memo. 2003-290
UNITED STATES TAX COURT
AMY H. O’BRIEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9958-02L. Filed October 14, 2003.
P filed a petition for judicial review pursuant to
secs. 6320 and 6330, I.R.C., in response to a
determination by R to leave in place a filed notice of
Federal tax lien.
Held: Because the record does not establish an
abuse of discretion by R in rejecting P’s offer in
compromise, R’s determination to proceed with
collection action is sustained.
Ansel B. Chaplin, for petitioner.
Nina P. Ching, for respondent.
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