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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.
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Last modified: March 27, 2008