Daniel J. Ford - Page 7

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          failed to balance the need for the efficient collection of taxes            
          with the concern that the collection action be no more intrusive            
          than necessary.                                                             
               Based on the foregoing, we hold that respondent’s                      
          determination to proceed with the collection of petitioner’s tax            
          liabilities for 1990, 1991, 1994, 1995, 1996, 1997, 1998, and               
          2002 was not an abuse of discretion.3                                       
               To reflect the foregoing,                                              

                                             An appropriate decision will             
                                        be entered.                                   

               3At trial, petitioner testified that his income and expenses           
          have changed since the filing of the collection information                 
          statement.  As of Dec. 8, 2005, petitioner testified that he                
          earned a $125,000 per year salary from Rosenthal Acura, that                
          petitioner’s housing and utilities expenses had risen to $5,000             
          per month, and that petitioner’s health care expenses had risen             
          to $700 per month.  Petitioner offered at trial to make a lump              
          sum payment of $50,000 and monthly installment payments of $900.            
          We note that the aforementioned changes to petitioner’s income              
          and expenses, even were we to consider them, would not alter our            
          decision that respondent’s determination did not constitute an              
          abuse of discretion.                                                        

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