- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12Last modified: November 10, 2007