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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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