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appropriate to collect by levy petitioner’s outstanding 1981,
1983, and 1996 Federal income tax liabilities (petitioner’s
outstanding tax liabilities). Neither the existence nor the
amounts of those liabilities have been placed in dispute.2 What
has been placed in dispute is respondent’s rejection of an offer-
in-compromise submitted by petitioner as a collection alternative
to respondent’s proposed levy. According to petitioner, his
offer-in-compromise should have been accepted, and respondent’s
determination to collect by levy the outstanding tax liabilities
is an abuse of discretion. Respondent disagrees, and, for the
following reasons, so do we.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Vermont.
Because the existence or the amounts of petitioner’s
outstanding tax liabilities are not in dispute, we see little
point in burdening this opinion with the history of how those
liabilities arose. Suffice it to say that as of July 2004, when
the relevant offer-in-compromise (the 2004 offer) was submitted
to respondent, those liabilities, including interest, penalties
and additions to tax, exceeded $600,000.
2 Consequently, we review respondent’s proposed collection
activity for abuse of discretion. Sego v. Commissioner, 114 T.C.
604, 610 (2000).
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Last modified: November 10, 2007