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determination relates to petitioners’ Federal income tax
liabilities for 1992, 1993, 1994, 1995, 1996, and 1997.
Petitioners’ liability for the underlying taxes, interest, and
penalties is not disputed. The issue for decision is whether
respondent’s rejection of petitioners’ three proposed
alternatives to collection constitutes an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time of filing the petition, petitioners resided in
Lebanon, Tennessee. Petitioner Donald G. Willis2 operates a
locksmith business as a sole proprietorship. Petitioner
subcontracts much of the locksmith work. In addition, petitioner
derives income from a part-time ministry. Petitioner Claudia A.
Willis is not employed outside the home.
On January 30, 2001, respondent sent to petitioners a final
notice of intent to levy with respect to petitioners’ outstanding
Federal income taxes, interest, and penalties for 1992 through
1997 (cumulative liability). On March 1, 2001, respondent
received petitioners’ timely request for a collection due process
hearing.
After submitting to respondent for consideration certain
personal financial information relating to petitioners, on May 9,
2 Hereinafter, unless otherwise indicated, references to
petitioner in the singular are to petitioner Donald G. Willis.
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