Henry M. Lloyd - Page 63




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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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