- 10 - revenue officer’s conclusion that petitioner could pay $59,676 in compromise of unpaid liabilities for 9 years exceeding $78,000. The determination also indicated that the proposed levy was necessary to induce payment, which was not an unreasonable conclusion in view of petitioner’s long history of delinquency. Based on the information considered by the Appeals officer, we cannot conclude that rejection of petitioner’s initial offer was an abuse of discretion or that rejection of petitioner’s amended offer would be an abuse of discretion. See Crisan v. Commissioner, T.C. Memo. 2003-318; Willis v. Commissioner, T.C. Memo. 2003-302; O’Brien v. Commisioner, T.C. Memo. 2003-290; Schulman v. Commissioner, T.C. Memo. 2002-129. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011