James J. and Veronica L. Crisan - Page 8
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failure to do so in this case is not an abuse of discretion.
Ramirez v. Commissioner, supra; Stein v. Commissioner, supra.
Petitioners did not produce any evidence to support their
contention that the filing of the notice of Federal tax lien
would impair their ability to pay their outstanding liabilities.
On the basis of the facts presented, this Court holds that
respondent did not abuse his discretion in sustaining the filing
of the notice of Federal tax lien.
In reaching these holdings, the Court has considered all
arguments made and, to the extent not mentioned, concludes that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: November 10, 2007