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returns is not an abuse of discretion. Londono v. Commissioner,
T.C. Memo. 2003-99; Ashley v. Commissioner, T.C. Memo. 2002-286;
Richter v. United States, 90 AFTR 2d 2002-5998, 2002-2 USTC par.
50,607 (C.D. Cal. 2002); AJP Mgmt. v. United States, 87 AFTR 2d
2001-347, 2001-1 USTC par. 50,184 (C.D. Cal. 2000); TTK Mgmt. v.
United States, 87 AFTR 2d 2001-350, 2001-1 USTC par. 50,185 (C.D.
Cal. 2000). The Commissioner may set reasonable priorities for
Internal Revenue Service staff as needed to effectively
administer the revenue laws. The decision not to accept the
offer in compromise submitted by petitioner on account of her
failure to file all required returns was an entirely reasonable
exercise of the Commissioner’s discretion in administering the
offer in compromise program.
We conclude that respondent’s determination to proceed with
collection as to petitioner’s 1988-89 tax liabilities was not an
abuse of discretion.
Accordingly,
Decision will be entered
for respondent.
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Last modified: May 25, 2011