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documents to make an offer-in-compromise. Petitioner did not
submit the necessary paperwork or any other information that
might have influenced Mr. Janish’s determination. Because of
petitioner’s consistent failure to communicate with Mr. Janish,
Mr. Janish committed no abuse of discretion sustaining the
proposed levy as an appropriate collection action under the
circumstances.
III. Conclusion
We hold that the Appeals Office did not abuse its discretion
in determining that respondent may proceed with the proposed
collection action. We have considered the remaining arguments of
both parties for results contrary to those discussed herein and,
to the extent not discussed above, conclude those arguments are
irrelevant, moot, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011