Robert Newstat - Page 12

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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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