- 22 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22Last modified: March 27, 2008