Edward F. Murphy - Page 2

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                    3.  Held, further, SO did not err in rejecting                    
               offer in compromise based, alternatively, on doubt as                  
               to collectibility and effective tax administration.                    
                    4.  Held, further, SO did not err in concluding                   
               hearing following P’s failures to meet various due                     
               dates, including due date for revised offer in                         
               compromise.                                                            
                    5.  Held, further, there were no improprieties in                 
               SO’s actions or hearing procedures.                                    
                    6.  Held, further, SO did not abuse her discretion                
               in determining that R may proceed by levy to collect                   
               P’s unpaid tax liability for 1999.                                     

               Timothy J. Burke, for petitioner.                                      
               Nina P. Ching and Maureen T. O’Brien, for respondent.                  

               HALPERN, Judge:  This case is before the Court to review a             
          determination made by one of respondent’s Appeals officers that             
          respondent may proceed to collect by levy unpaid taxes with                 
          respect to petitioner’s 1999 tax year.  We review the                       
          determination pursuant to section 6330(d)(1).                               
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts have been rounded to the nearest dollar.                     
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with accompanying exhibits, is incorporated           
          herein by this reference.                                                   






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