Sal and Ruth Alaniz - Page 2

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               David P. Leeper, for petitioners.                                      
               Erin K. Huss, for respondent.                                          


                                 MEMORANDUM OPINION                                   
               NIMS, Judge:  This case is before the Court on both parties’           
          motions for summary judgment pursuant to Rule 121.  The instant             
          proceeding arises from a petition for judicial review filed in              
          response to a Notice Of Determination Concerning Collection                 
          Action(s) Under Section 6320 and/or 6330.  Unless otherwise                 
          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.  The                  
          parties do not challenge the Court’s jurisdiction over this case.           
          Petitioners do not dispute their liability for underlying taxes,            
          penalties, and interest.  The sole issue for decision is whether            
          respondent’s rejection of petitioners’ offer in compromise                  
          constitutes an abuse of discretion.                                         
                                     Background                                       
               Some of the facts are stipulated and are incorporated herein           
          by this reference.  At the time the petition was filed in this              
          case, petitioners resided in El Paso, Texas.                                
               Petitioner Sal Alaniz is a 73-year-old insurance salesman              
          who has been diagnosed with high blood pressure and severe vision           
          impairment.  Petitioner Ruth Alaniz assists her husband in the              






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