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without published opinion 886 F.2d 1316 (6th Cir. 1989).
Petitioner appears to argue that detailed income and expense
information was unnecessary because his expenses exceeded his
income; thus, even if he had constructive income, it was entirely
offset by the imputed rent he paid to Ms. Bernd. As noted supra,
however, respondent required complete financial data to evaluate
petitioner’s OIC. See Roman v. Commissioner, supra. Petitioner
cannot selectively withhold information because he believes it to
be irrelevant.
We conclude that petitioner failed to provide complete
financial information to respondent. Respondent’s rejection of
petitioner’s OIC therefore does not constitute abuse of
discretion. See id.; Willis v. Commissioner, supra. With
respect to respondent’s determination of petitioner’s ability to
pay, we share petitioner’s concern about the statement in the
Appeals memorandum that petitioner’s $4,200 line of credit
constitutes an asset. We can find no support in the IRM for this
position. Based on our resolution of the case, however, we do
not decide whether this determination is correct. In reaching
our holding, we have considered all arguments made, and, to the
extent not mentioned, we conclude that they are moot, irrelevant,
or without merit.
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