- 18 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011