- 7 - be no basis for the Court to hold that there was an abuse of discretion with respect to the offer-in-compromise.3 Petitioner’s final argument is that a portion of his tax liabilities had been satisfied through offset and other collection by respondent. However, the specific amounts of petitioner’s tax liabilities that remain unpaid have not been addressed by him, and there is no evidence that respondent is attempting to collect more than petitioner’s unpaid balance. In summary, before the scheduled section 6330 hearing, petitioner’s sole defense to the proposed levy was his challenge to the underlying tax liability. Petitioner did not attend the scheduled hearing, and through the time of the final notice he did not offer spousal defenses, challenges to the appropriateness of the collection action, or collection alternatives. We, accordingly, hold that respondent did not commit error or abuse his discretion in his determination to proceed with collection. To reflect the foregoing, Decision will be entered for respondent. 3It should be noted that petitioner’s offer-in-compromise was with respect to doubt as to liability, which would address the merits of the underlying liability. Since petitioner is precluded from questioning the underlying liabilities, his offer would not provide him any relief in the setting of this proceeding.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011