Albert M. Kun - Page 8

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          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.                                           





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