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1997 was inadequate. The Appeals officer concluded that
petitioner’s monthly disposable income was $463.39 and that the
monthly disposable income for the next 48 months totaled
$22,242.72. After conceding the liabilities for 1993, 1994, and
1995 the Appeals officer concluded that the offer of $100 was
“paltry” considering the outstanding debt of $4,249.07 for 1996
and 1997.
On February 24, 2004, the Appeals Office issued the notice
of determination sustaining its determination to proceed with
collection of the outstanding liabilities for the 1996 and 1997
taxable years. As indicated, the notice of determination also
indicated that collection action would not be sustained with
respect to the outstanding tax liabilities for 1993, 1994, and
1995, and that said liabilities should be abated.
Discussion
This Court has jurisdiction under section 6330 to review the
Commissioner’s administrative determinations. Sec. 6330(d).
Where, as here, the validity of the underlying tax liability is
not at issue, we review the determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza
v. Commissioner, 114 T.C. 176, 183 (2000). In so doing, we do
not conduct an independent review of what would be an acceptable
offer in compromise. Van Vlaenderen v. Commissioner, T.C. Memo.
2003-346. We review only whether the Appeals officer’s refusal
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