Thomas E. Roberts - Page 12

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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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