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Cir. 1994). In that regard, summary judgment is intended to
expedite litigation and avoid unnecessary and expensive trials.
Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). There
remains no genuine issue as to any material fact in this case.
Petitioners had the opportunity to contest the underlying
merits of their 1991, 1992, 1993, and 1994 income tax
deficiencies. Accordingly, our review is limited to the
administrative determination for abuse of discretion. Sec.
6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604, 610 (2000).
Petitioners allege an abuse of discretion by respondent due to
the fact that the Appeals officer rejected petitioners’ $1,800
offer in compromise. That decision was made based on information
available to respondent showing that petitioners owned real
property in Fort Pierce, Florida, which was sufficient in value
to satisfy all outstanding tax liabilities.
Petitioners contend, in effect, that their son was the true
owner of the Fort Pierce realty and that, in some manner,
petitioners were nominees and not true owners. Petitioners,
however, provided no evidence to respondent to verify or
substantiate their contention. Conversely, respondent provided
evidence to petitioners showing that they were the sole owners of
the subject realty at the time the Government’s assessments were
made and the Federal tax lien arose. Under the circumstances,
petitioners have not shown an abuse of discretion by respondent
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