- 8 - copies of the Forms 4340,2 Appeals Officer Wong’s failure to give them to petitioner at the hearing is not an abuse of her discretion. See id. 2. Petitioner’s Offer-in-Compromise Petitioner further asserts that it was an abuse of discretion for Appeals Officer Wong to reject his offer-in- compromise. According to petitioner, Appeals Officer Wong (1) failed to apply Internal Revenue Manual section “5.15.1.4.3" for evaluating petitioner’s Forms 433-A and 433-B and (2) failed “to make a finding of net income” for purposes of an installment agreement. In his filings with the Court, petitioner did not explain his contention regarding the Internal Revenue Manual and offered no evidence in support of his position that Appeals Officer Wong did not properly evaluate his collection information. Upon review of the record, it is clear that Appeals Officer Wong carefully considered petitioner’s collection information and, on the basis of that information, determined that petitioner’s 2There is no evidence, and petitioner did not allege, that he ever requested copies of the Forms 4340 from the Appeals officer at or before the hearing.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011