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Conclusion
Petitioner has offered no credible evidence showing that
respondent’s determination was arbitrary, capricious, or without
sound basis in law. The Appeals officer verified that applicable
law and administrative procedures had been met and determined
that the proposed collection action balances the need for the
efficient collection of taxes with the legitimate concern of the
taxpayer that any collection action be no more intrusive than
necessary. Based upon our review of the relevant evidence and
law in this case, we sustain the determination of respondent to
proceed with the proposed levy to collect petitioner’s unpaid
income tax liabilities for 1982, 1983, and 1984.
We have considered the arguments of the parties that were
not specifically addressed in this opinion. Those arguments are
either without merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011