Keith and Cherie Orum - Page 22

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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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