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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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