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Memo. 2004-288; Tolotti v. Commissioner, T.C. Memo. 2002-86,
affd. 70 Fed. Appx. 971 (9th Cir. 2003). Because petitioner
raised only arguments the Tax Court has uniformly determined to
be without merit, the settlement officer appropriately concluded
the meeting.
Petitioner’s arguments do not present justiciable issues;
they ignore established law and give no basis for his claim that
respondent abused his discretion in sustaining the Federal tax
lien. This Court concludes that respondent’s determination to
proceed with collection of the tax liabilities assessed against
petitioner for 1999 was not an abuse of discretion.
In reaching these holdings, the Court has considered all
arguments made and, to the extent not mentioned, concludes that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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