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Petitioner failed to show that $5,243.13 of his bankruptcy estate
was used to pay his 1994-96 taxes.
B. Whether Respondent’s Determination To Proceed With
Collection Was an Abuse of Discretion
Petitioner contends that respondent’s determination to
proceed with collection was an abuse of discretion because he
spent about $18,000 in prosecuting various claims against the
Government. We disagree. Petitioner is entitled to no credit
against his unpaid tax based on those claimed costs.
We conclude that respondent’s determination to proceed with
collection of his 1994-96 tax liabilities was not an abuse of
discretion.
Decision will be
entered for respondent.
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Last modified: May 25, 2011