- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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