- 9 - Appeals. See sec. 6330(c)(2); Magana v. Commissioner, 118 T.C. at 493. Even if petitioner had raised an OIC as a collection alternative, the result in this case would not change. Where a taxpayer is noncompliant with Federal tax laws or does not provide current financial information, the Commissioner’s refusal to process an OIC is not an abuse of discretion. Roman v. Commissioner, T.C. Memo. 2004-20; Rodriguez v. Commissioner, T.C. Memo. 2003-153. Petitioner’s failure to file his 2001 tax return and provide respondent with current financial information would therefore preclude us from finding an abuse of discretion. On the basis of our review of the record, we conclude that respondent satisfied the requirements of section 6330 and did not abuse his discretion in sustaining the proposed collection action against petitioner. Respondent’s determination therefore is sustained. In reaching our holding, we have considered all arguments made, and, to the extent not mentioned, we conclude that they are moot, irrelevant, or without merit. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
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