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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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