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reasonably concluded that there are sufficient income and assets
to satisfy the tax liability. On the basis of respondent’s
consideration of petitioners’ information, we conclude that
respondent’s refusal to enter into an offer-in-compromise was not
an abuse of discretion. See Crisan v. Commissioner, T.C. Memo.
2003-318 (held the Commissioner’s refusal to enter into an offer-
in-compromise was not an abuse of discretion on the basis of a
review of the financial information submitted to the Appeals
officer).
As a result, we hold that the determination to proceed with
collection for 1999 was not an abuse of respondent’s discretion,
and the proposed collection action is sustained.
In reaching our holdings herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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