Donald A. and Virginia M. Singer - Page 7

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         Consequently, respondent’s refusal to enter into an offer in                 
         compromise was not an abuse of discretion.  See Crisan v.                    
         Commissioner, T.C. Memo. 2003-318 (holding the Commissioner’s                
         refusal to enter into an offer in compromise was not an abuse of             
         discretion on the basis of a review of the financial information             
         submitted to the settlement officer).                                        
              On the basis of the foregoing, we conclude that all the                 
         requirements of section 6330 have been satisfied, and respondent             
         may proceed with his proposed collection actions.                            
              To reflect the foregoing,                                               

                                                 Decision will be entered             
                                       for respondent.                                















         (...continued)                                                               
          doubt as to collectibility.  Thus, we believe that it is neither            
          necessary nor productive to remand this case to IRS Appeals to              
          consider petitioners' arguments.  See Lunsford v. Commissioner,             
          117 T.C. 183, 189 (2001).                                                   





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