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respondent’s Appeals officer to sustain the lien and reject
petitioners' offer to compromise their 1995, 1996, and 1997
liabilities of $7,832.90 for $100. Because of the value of
petitioners’ assets, we hold that it was not an abuse of
discretion.
Background
The parties submitted this case fully stipulated under Rule
1221. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners, Mr. Razo and
Mrs. Razo, resided in El Paso, Texas, at the time they filed
their petition. This Court, in an Order dated November 19, 2003,
denied a motion by respondent to dismiss for lack of
jurisdiction, as supplemented.
Petitioners filed joint Federal income tax returns for 1995,
1996, and 1997. Each of these returns showed tax due, but
petitioners did not submit payment with the returns. On March 1,
2002, respondent issued petitioners a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under I.R.C. Section 6320,
listing their total 1995, 1996, and 1997 liabilities as
$7,832.90. On March 4, 2002, respondent filed a notice of
Federal tax lien in El Paso County, Texas.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time the petition was
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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