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