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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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