Russell L. Voorhees - Page 4

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          $15,000 on assets that he owned at the time of the consideration            
          of his offer.                                                               
               Respondent rejected petitioner’s offer and countered with an           
          offer to permit petitioner to make $100 monthly installment                 
          payments to pay the outstanding liabilities.  Petitioner rejected           
          those terms, and respondent, on March 14, 2002, issued a notice             
          of determination, advising petitioner that respondent intended to           
          proceed with enforced collection.  Petitioner filed an Amended              
          Petition with this Court on May 3, 2002.                                    
                                      OPINION                                         
               We have held in an Order dated January 23, 2004, that                  
          petitioner is precluded from contesting the underlying merits of            
          his 1991 income tax liability, and petitioner does not contest              
          his self-assessed 1996 liability.  Accordingly, our review of the           
          administrative determination is for abuse of discretion.  Sec.              
          6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604, 610 (2000).              
               Petitioner contends there was an abuse of discretion due to            
          respondent’s rejection of petitioner’s $1,500 offer in                      
          compromise.  That decision was made based on information                    
          available to respondent showing that petitioner was able to                 
          satisfy the outstanding tax liabilities.                                    
               Petitioner contended at trial that the 1991 income tax                 
          liability should have been about one-half of the $2,717 amount to           
          which he had agreed in the decision entered October 18, 1995.               






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