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abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610
(2000).
At the hearing, the Commissioner is not required to provide
the taxpayer with any form listing the amount the taxpayer owes.
Nestor v. Commissioner, 118 T.C. 162, 166-167 (2002). In any
event, petitioner has received copies of his transcript of
account and Forms 4340 for each of the years in issue. Villwock
v. Commissioner, T.C. Memo. 2002-235 n.4. Accordingly, we
conclude that respondent did not abuse his discretion by not
providing this information to petitioner at the hearing.
Respondent reviewed the financial information provided to
him by petitioner. The Appeals officer followed prescribed
guidelines to determine whether the second OIC was adequate and
should be accepted. Sec. 7122(c)(1). The Appeals officer
allowed petitioner national standard expenses in accordance with
section 7122(c)(2). In accordance with the regulations,
respondent prepared a monthly income and allowable expense
analysis, based on all of the information provided by petitioner,
and determined that petitioner could pay $472 per month toward
petitioner’s outstanding 1989, 1990, 1991, 1992, 1993, and 1994
tax liabilities. See sec. 301.7122-1T(b)(3), Temporary Proced. &
Admin. Regs., 64 Fed. Reg. 39020 (July 21, 1999). We have
reviewed those computations, and we find them to be reasonable.5
5 We note that under petitioner’s own figures $346, and not
$200, per month was available to be applied to petitioner’s
(continued...)
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