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We must decide whether respondent abused respondent’s
discretion in determining to proceed with the collection action
as determined in the notice of determination with respect to
petitioner’s taxable years 1997, 1998, 1999, and 2000. We hold
that respondent did not abuse respondent’s discretion.
Background
Virtually all of the facts have been stipulated by the
parties and are so found.
At the time petitioner, who retired as an employee of the
U.S. Government in 2002, filed the petition in this case, his
legal residence was in Baltimore City, Maryland.
On various dates, respondent assessed petitioner’s Federal
income tax (tax), as well as any additions to tax and interest as
provided by law, for each of his taxable years 1997, 1998, 1999,
and 2000. (We shall refer to those assessed amounts, as well as
any interest as provided by law accrued after the respective
assessment dates, as petitioner’s unpaid liabilities for 1997,
1998, 1999, and 2000.) After respondent made the assessments for
petitioner’s taxable year 1997, respondent abated certain as-
sessed amounts of petitioner’s tax, additions to tax, and inter-
est as provided by law for that year. Thereafter, on different
dates in 2003 and 2004, respondent applied as credits to the
remaining unpaid liability for 1997 certain overpayments from
certain other taxable years of petitioner. Thereafter, on August
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