Scott Roman - Page 14

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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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