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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.
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Last modified: May 25, 2011