Shirley Dean Powers, a.k.a. Shirley Powers Gilchrist - Page 4

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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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