- 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 action. 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 Division. 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