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not produced any evidence that he had reasonable cause or a lack
of willful neglect in failing to timely file his 1992 return and
failing to pay the taxes shown on his 1992, 1998, and 2000
returns.
Petitioner has not alleged or proven that the settlement
officer abused her discretion in finding that he had the ability
to pay his tax liabilities in full. Because petitioner has
failed to present grounds on which this Court could find that the
settlement officer abused her discretion in sustaining the Notice
of Federal Tax Lien on petitioner's property, the Court sustains
respondent's administrative determination to proceed with
collection against petitioner.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
A decision will be entered for
respondent.
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Last modified: May 25, 2011