- 15 - admit that both father and daughter were at that time, and still are, covered under their medical insurance policy. Despite ample evidence to the contrary, petitioners have maintained that they are unable to make more than the $100 proposed in their OIC, an amount that respondent’s Appeals officer did not abuse her discretion in rejecting. We therefore hold that respondent’s determination was not an abuse of discretion and that respondent may proceed with his collection of the tax liability by levy upon petitioners’ property. Decision will be entered for respondent.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16Last modified: March 27, 2008