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Initially, the filing of a joint return does not, per se,
make the joint filers equal “owners” of any refund of tax from
said return. Instead, each joint filer is apportioned an
interest in the overpayment to the extent he or she contributed
to the overpayment. See Gens v. United States, 230 Ct. Cl. 42,
673 F.2d 366 (1982). In that regard, petitioner has not shown
that any portion of the overpayments for the years 1999 through
2002 was attributable to his wife. Without such information, we
cannot find that there was any abuse of discretion in not
adjusting or reversing the offsets.
Conclusion and Holding--Although petitioner’s filings were
sparse and terse, we have carefully considered his summary
contentions. To the extent that we have not addressed any
particular aspect of his contentions, they are not worthy of
further consideration or comment. We hold that respondent’s
determination to pursue collection by filing Notices of Federal
Tax Liens was not an abuse of discretion. In this case where
petitioner has not shown how a compromise of his liability would
promote effective tax administration coupled with his admission
that his assets are sufficient to pay the outstanding tax
liability, respondent’s refusal to consider alternatives is not
an abuse of discretion. Petitioner’s contention in this regard
has been that the filing of a lien will affect his credit and
ability to sell or transfer assets. Those reasons do not, per
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