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petitioner seems to be a random number not derivable from or
bearing any particular relationship to the expenses upon which it
is purportedly premised. As a result, the Court is unable to say
that respondent at any point arbitrarily or unreasonably failed
to take into account meaningful and pertinent information about
petitioner’s financial situation that would render the
determination to proceed with levy an abuse of discretion. See
Orum v. Commissioner, supra; Etkin v. Commissioner, supra.
As much as we would like to assist petitioner, in light of
her repeated failure to take advantage of opportunities to
provide adequate documentation of her apparently changed
financial circumstances, we simply do not have before us evidence
to show that a remand would be appropriate and productive. The
Court will sustain respondent’s collection action.
To reflect the foregoing,
An appropriate order
denying respondent’s motion
for summary judgment and
decision for respondent will
be entered.
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Last modified: May 25, 2011