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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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Last modified: May 25, 2011