Ralph Tashjian - Page 18

                                       - 18 -                                         
               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