- 4 - 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 respondentPage: Previous 1 2 3 4 5 Next
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