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complete financial information, in particular a Form 433-A,
before respondent will be considered to have committed an abuse
of discretion in declining to accept an offer in compromise or
installment agreement. Id. Because petitioner did not heed this
warning, the Court lacks any ground for concluding that
respondent acted arbitrarily or capriciously in determining to
proceed with levy for 1999.
Thus, although the Court remains sympathetic to petitioner’s
health and economic situation and has given petitioner every
chance to demonstrate his entitlement to relief, we are
constrained to sustain respondent’s supplemental collection
determination as it pertains to the 1999 taxable year. To
reflect the foregoing and the Court’s previous ruling,
Decision will be entered
for respondent.
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Last modified: May 25, 2011