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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.
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Last modified: May 25, 2011