Leonard O. Parker, Jr. - Page 15

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              Petitioner has not alleged, and the record contains no                  
         evidence, that respondent committed any erroneous or dilatory                
         acts requiring abatement of interest.  Thus, the Court concludes             
         respondent's decision not to abate interest is not an abuse of               
         discretion.                                                                  
              Petitioner asserts he did not receive proper notice of the              
         filing of the NFTL with respect to his unpaid income tax                     
         liabilities for the years at issue.  Under section 6320 the                  
         Secretary shall furnish the person described in section 6321 with            
         written notice of the filing of a notice of lien under section               
         6323.  The notice may be sent by certified mail to the person’s              
         last known address not more than 5 business days after the day of            
         filing the Federal tax lien.  Sec. 6320(a)(2).  Petitioner was               
         duly sent notice within 5 business days of the filing of the                 
         Federal tax lien.  Thus, the Court concludes respondent did not              
         abuse his discretion in determining petitioner received proper               
         notice of the filing of the NFTL.                                            
              Finally, respondent did not abuse his discretion in                     
         determining further consideration of collection alternatives was             
         futile.  Petitioner repeatedly failed to cooperate and respond to            
         respondent’s requests for financial information or to submit a               
         processable offer-in-compromise.                                             
              Accordingly, the Court holds that respondent’s determination            
         upholding the Federal tax lien was not an abuse of his                       






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