Richard Mark Hansen - Page 15

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          managerial act requiring the abatement of interest with respect             
          to the taxable years 1997, 1998, and 2000.  See sec. 6404(e).               
               Petitioner has not alleged or proven that the settlement               
          officer abused his discretion in finding that petitioner had the            
          ability to pay his tax liabilities in full.  Because petitioner             
          has failed to present grounds on which this Court could find that           
          the settlement officer abused his discretion in sustaining the              
          Notice of Federal Tax Lien on petitioner’s property, the Court              
          sustains respondent’s administrative determination to proceed               
          with collection against petitioner.                                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              

                                                  Decision will be                    
                                             entered for respondent.                  




















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