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The uncontested record before us indicates that Officer
Clark’s adjustments were not arbitrary, capricious, or without
sound basis in law or fact. See Woodral v. Commissioner, supra
at 23. Officer Clark made reasonable adjustments by evaluating
petitioners’ disclosures on and attachments to their Form 433-A,
petitioners’ last filed Federal and State income tax returns, and
the Service’s national standards. Accordingly, respondent did
not abuse his discretion in rejecting petitioners’ proposed
installment agreement and sustaining the proposed collection
action.
We conclude that there is no genuine issue of material fact
requiring a trial in this case, and we hold that respondent is
entitled to the entry of a decision sustaining the proposed levy
as a matter of law.
An appropriate order and
decision will be entered.
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Last modified: November 10, 2007