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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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