- 7 - 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).Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011