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Petitioner did not establish that the settlement officer’s
determination was an abuse of discretion. We hold, therefore,
that the settlement officer did not abuse her discretion by
determining that the lien on petitioner’s property was
appropriately filed and would remain in effect until petitioner’s
2000 and 2001 tax liabilities were satisfied.
To reflect the foregoing,
Decision will be entered
for respondent.
9(...continued)
standards promulgated by respondent for use in calculating a
taxpayer’s allowable expenses.
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