- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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