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petitioner’s ability to pay his outstanding tax liabilities.6
After all, it doesn’t take much of a financial structure to
support a payment in excess of $1,000.
Taking into account all of the facts and circumstances, we
are satisfied that respondent’s determination to collect by levy
petitioner’s outstanding tax liabilities is supported in law and
in fact. It follows that the determination is not an abuse of
discretion, see Freije v. Commissioner, 125 T.C. 14 (2005), and
respondent may proceed with collection as proposed in the above-
referenced notice of determination.
To reflect the foregoing,
Decision will be entered
for respondent.
6 For example, the parties stipulated that at the time the
2004 offer was under consideration by the settlement officer,
petitioner “had a savings certificate of deposit with an account
balance of $28,000”.
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Last modified: November 10, 2007