- 8 - We infer that the failure to eliminate petitioner’s total liability for the 3 years in issue by a single payment of $100, a result that petitioner’s representative had achieved in other cases, led to the pursuit of this proceeding in response to what otherwise would be regarded as a favorable determination. Petitioner has not offered, nor have we found in the record, any reason why the determination to suspend collection and not to pursue levies is an abuse of discretion. That his representative achieved a $100 compromise of liabilities in other cases is irrelevant. We conclude that the material facts are not in dispute and that respondent is entitled to judgment as a matter of law. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011