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circumstances satisfied the conditions necessary for compromise
of a tax liability. Evaluation of potentially pertinent grounds
for compromise, such as doubt as to collectibility or a showing
of economic hardship, would require complete financial data. The
record is equally bereft of any indication of exceptional
circumstances suggesting that collection here could undermine
public confidence in tax administration. Hence, the Court holds
that respondent’s determination to proceed with collection of
petitioner’s tax liabilities was not an abuse of discretion. See
e.g., Van Vlaenderen v. Commissioner, T.C. Memo. 2003-346;
Neugebauer v. Commissioner, T.C. Memo. 2003-276.
We shall grant respondent’s motion.
To reflect the foregoing,
An appropriate order
granting respondent’s motion
for summary judgment and
decision for respondent will
be entered.
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