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This proceeding arises from a petition for judicial review
filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 (notice of
determination) sent to petitioner on February 19, 2005. Pursuant
to sections 6320(c) and 6330(d), petitioner seeks review of
respondent’s determination sustaining the filing of a notice of
Federal tax lien against petitioner. The issue for decision is
whether respondent abused his discretion in rejecting an offer-
in-compromise (OIC) that petitioner submitted for the taxable
year 2002.
Background
Some of the facts have been stipulated, and they are so
found. The record consists of the stipulation of facts and
supplemental stipulation of facts with attached exhibits, an
additional exhibit admitted during trial, and the testimony of
petitioner. At the time of filing the petition, petitioner
resided in San Francisco, California.
Petitioner was 43 years old at the time of trial. He has
been sporadically employed throughout his adulthood. Social
Security records covering the taxable years 1978 through 2003
indicate petitioner’s annual wage income has never exceeded
$19,432. The records also indicate petitioner earned no wage
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