Robert Conde Del'Giudice - Page 9

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          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.                    
               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               
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          

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