Perry Goldman and Sandra Goldman - Page 4

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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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