Kathryn D. Mills - Page 9

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                                     Discussion                                       
               The Court may grant summary judgment where there is no                 
          genuine issue of material fact and a decision may be rendered as            
          a matter of law.  Rule 121(b); Sundstrand Corp. v. Commissioner,            
          98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994).  We             
          conclude that there is no genuine issue of material fact regard-            
          ing the questions raised in respondent’s motion.                            
               Petitioner did not dispute the existence or the amount of              
          petitioner’s unpaid liability for 2000 at the Appeals Office                
          hearing or in the petition that she filed in this case.  We shall           
          review the notice of determination for abuse of discretion.  See            
          Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commis-             
          sioner, 114 T.C. 176, 181-182 (2000).                                       
               The settlement officer considered all of the allegations and           
          contentions in petitioner’s Form 12153 and in her submissions to            
          such settlement officer.  During the Appeals Office hearing that            
          the settlement officer held with petitioner, the settlement                 
          officer discussed possible collection alternatives with her,                
          including posting a bond, substituting collateral, or paying in             
          full petitioner’s unpaid liability for 2000.  In addition, the              
          settlement officer considered whether there were grounds under              
          section 6323(j) to withdraw the notice of lien.  At no time in              
          connection with the Appeals Office hearing did petitioner submit            
          an offer-in-compromise to the settlement officer or request an              






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