- 15 -
Petitioners have not introduced any evidence as to specific
mistakes or irregularities in respondent’s assessment procedure
or determination process. Petitioners introduced no evidence at
trial to show that respondent’s determination was “arbitrary,
capricious, clearly unlawful or without sound basis in fact or
law.” Id. Therefore, we conclude that respondent did not abuse
his discretion, and we sustain respondent’s determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011