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able to avoid paying the total tax liability by filing for
bankruptcy. In other words, respondent believed that the impact
of petitioner’s filing for bankruptcy on respondent’s ability to
collect petitioner’s unpaid tax would be minimal. We are not
prepared to find that respondent’s rejection of petitioner’s
offer-in-compromise was arbitrary, capricious, or without sound
basis in fact or law.
On the basis of this record, we conclude that petitioner is
liable for the additions to tax as determined by respondent for
all years at issue and that respondent did not abuse his
discretion in rejecting petitioner’s offer-in-compromise.
Respondent’s determination that the Federal tax levies were
appropriate in these cases is sustained.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: November 10, 2007