Anthony Edward and S.F. O'Connor - Page 10

                                        - 9 -                                         
          6320 or 6330.  See Speltz v. Commissioner, supra at 180.                    
          Accordingly, we need not and do not decide whether petitioners              
          would suffer an economic hardship if respondent pursued a levy              
               On the basis of our review of the record, we conclude that             
          respondent satisfied the requirements of section 6330(c) and did            
          not abuse his discretion by rejecting petitioners’ OIC and                  
          sustaining the notice of Federal tax lien filed against                     
          petitioners.  Respondent’s determination therefore is sustained.            
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

Page:  Previous  1  2  3  4  5  6  7  8  9  10  

Last modified: May 25, 2011