Randall G. Van Vlaenderen - Page 10

                                       - 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