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information would be forthcoming, no such supporting
documentation was provided. Accordingly, the Appeals Office only
had petitioner’s self-serving statements to support his
contention.
We find that the Appeals Office considered petitioner’s
offer in compromise and, in light of his failure to provide
supporting documentation, respondent’s determination to reject
petitioner’s offer in compromise was not an abuse of discretion.
Therefore, respondent’s determination to proceed with collection
is therefore sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing and respondent’s concession of an
adjustment made in the notice of deficiency dated October 20,
1999,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011