- 8 -
determined that the OIC was not appropriate on the basis of doubt
as to collectibility because petitioner can pay more of his tax
liability over the collection period. The Court, having reviewed
as exhibits the financial information submitted to the Appeals
officer, concludes that the Appeals officer could have reasonably
determined that petitioner’s OIC was insufficient. See Kun v.
Commissioner, T.C. Memo. 2004-209, affd. 157 Fed. Appx. 971 (9th
Cir. 2005); Crisan v. Commissioner, T.C. Memo. 2003-318.
Conclusion
Respondent’s determination to proceed with collection action
was not an abuse of discretion.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011