- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011