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action is precluded by [petitioner’s] chronic non-compliance.”
We understand respondent’s determination to mean that
petitioner’s extensive history of noncompliance with the tax law
disqualifies her from eligibility for an offer in compromise or
other collection alternative. Petitioner offers us no evidence
and no argument regarding this critical part of respondent’s
determination. Even if petitioner had raised the issue, however,
we simply cannot ascertain from the record that respondent’s
determination regarding petitioner’s eligibility for an offer in
compromise was an abuse of discretion under the circumstances of
this case.
We have considered the remaining arguments of both parties
for results contrary to those expressed herein and, to the extent
not discussed above, find those arguments to be irrelevant, moot,
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011