- 11 - compromise a tax liability must be submitted according to the procedures and in the form and manner described by the Commissioner. Sec. 301.7122-1(d)(1), Proced. & Admin. Regs. The offer must contain all of the information prescribed or requested by the Commissioner. Id. It is notable that petitioner has not denied that he has failed to provide all the necessary information for consideration of his OIC and in fact offered to the Court at the June 12, 2006, hearing his “latest” OIC. The Court finds that petitioner did not offer to Appeals an alternative means of collection. See Chandler v. Commissioner, T.C. Memo. 2005-99; AllGlass Sys., Inc. v. Commissioner, 330 F. Supp. 2d 540, 547 (E.D. Pa. 2004). In the absence of a valid issue for review, the Court concludes that respondent is entitled to judgment as a matter of law sustaining the notice of determination dated March 9, 2004. Respondent’s determination to proceed with collection action was not an abuse of discretion. The Court will grant respondent’s motion for summary judgment. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011