- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011