John P. and Sharon Lynn - Page 9

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          addressed the issues raised by petitioner.  Furthermore, the                
          record demonstrates that Settlement Officer Munson properly                 
          verified that all applicable laws and administrative procedures             
          were followed and balanced the need for the efficient collection            
          of taxes with the concern that the collection action be no more             
          intrusive than necessary.                                                   
               On the basis of the foregoing, we hold that the                        
          determination of respondent’s Appeals Office to proceed with the            
          collection of petitioners’ tax liabilities for 1994 was not an              
          abuse of discretion.                                                        
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                                        respondent.                                   























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