Marc Perkel - Page 12

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          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.                







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