- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011