-4-
liabilities for those years, see sec. 6330(c)(2)(B), we review
Appeals' determination for an abuse of discretion, see Sego v.
Commissioner, supra at 610. Petitioner claims no specific abuse
of discretion on the part of Appeals in making its determination,
nor do we find any such abuse. As we understand petitioner’s
sole position in this case, he claims that he has a mental
condition (similar to paranoia) resulting from racial injustice
against his ancestors and that this condition and injustice
entitle him to relief from the lien. Those allegations, however,
do not establish that Appeals abused its discretion as to any
part of the determination at issue. We sustain Appeals’
determination in its entirety. We have considered all arguments
made by petitioner for a contrary holding and found those
arguments not discussed herein to be without merit. To reflect
the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011