- 11 -
126 T.C. 237, 246-248 (2006); Elmore v. Commissioner, T.C. Memo
2003-123.
Petitioner has not addressed his financial circumstances
that were determined in the notice to preclude alternative means
of collection. He raises new issues, such as claims that certain
assets are exempt, only in his reply brief, and therefore those
issues will not be considered. Again his arguments are not
supported by evidence or authority. We need not and will not
address all of them. The abuse of discretion standard requires
the Court to decide whether the challenged determination was
arbitrary, capricious, or without sound basis in fact or law.
See Woodral v. Commissioner, 112 T.C. 19, 23 (1999). After
considering petitioner’s lengthy submissions and the lack of
evidentiary or legal support for his claims, we conclude that he
has shown neither error nor abuse of discretion in the notice of
determination.
Decision will be entered
for respondent.
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