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unspecified business expenses deductions. Nonetheless, despite
having been given every opportunity over a period in excess of 8
months between the issuance of our prior opinion and the
supplemental notice of determination, petitioner has failed to
produce an iota of supporting documentation substantiating such a
claim. The Court is therefore not in a position to afford
petitioner any relief in this regard.
2. Review for Abuse of Discretion
In evaluating the propriety of a collection determination,
the Court reviews for abuse of discretion those issues enumerated
in section 6330(c)(2)(A); i.e., spousal defenses, challenges to
the appropriateness of the collection action, and offers of
collection alternatives. Action constitutes an abuse of
discretion under this standard where it is arbitrary, capricious,
or without sound basis in fact or law. Woodral v. Commissioner,
112 T.C. 19, 23 (1999).
Here, petitioner has at various junctures expressed an
apparent interest in a collection alternative such as an
installment agreement. However, again despite substantial
additional time to meet the prerequisites for consideration of an
alternative collection arrangement, the scenario before the Court
remains virtually unchanged from that described within the
context of the 1985 year in Newstat v. Commissioner, supra. We
in that opinion stressed the concept that a taxpayer must supply
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