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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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Last modified: May 25, 2011