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people her age, she faces the possibility of medical expenses in
the future. Nevertheless, the record shows that petitioner has
sufficient assets to pay the amounts respondent seeks to collect,
even though petitioner might prefer to retain those assets for
other purposes.
Accordingly, we sustain respondent’s determination not to
release the notice of Federal tax lien due to tax liabilities
from 1996, 1997, 1998, 2000, and 2001. We also sustain
respondent’s determination to proceed with levy action for 2000
and 2001. The Appeals officer clearly did not abuse her
discretion, and the amounts of the liabilities for all years are
undisputed.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011