Robert and Grace Bergevin - Page 22




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          collection.  The only issue before us is whether there was an               
          abuse of discretion in refusing the offer that petitioners made.            
          See Speltz v. Commissioner, 124 T.C. 165, 180 (2005), affd. 454             
          F.3d 782 (8th Cir. 2006).  The settlement officer adequately                
          considered the arguments and made a reasoned determination.  We             
          hold that there was no abuse of discretion in that process.                 

                                             Decision will be entered                 
                                        for respondent.                               
































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