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officer, petitioner’s offer of $139,776 in petitioner’s June 24,
2005 offer-in-compromise did not equal or exceed that RCP.
On the record before us, we find that the settlement officer
took into consideration whether the proposed collection action
with respect to petitioner’s unpaid liabilities for 1990, 1991,
1992, 1994, 1996, 1997, and 2002 balanced the need for the
efficient collection of those liabilities with the legitimate
concern of petitioner that that collection action be no more
intrusive than necessary. See sec. 6330(c)(3)(C).
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
making the determinations in the notice of determination with
respect to petitioner’s unpaid liabilities for 1990, 1991, 1992,
1994, 1996, 1997, and 2002. On that record, we sustain those
determinations.
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and decision for respondent
will be entered.
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