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evidence that petitioners specified in writing that the proceeds
be applied to their income tax liability instead.
On the basis of the record before the Court, and with the
exception of the failure to pay penalty for income tax year 1997
which respondent concedes, petitioners are liable for the taxes,
additions to tax, and interest as determined by respondent. We
further find that respondent did not abuse his discretion in
rejecting petitioners’ offers-in-compromise. Thus, respondent's
determination that the Federal tax levies were appropriate in
these cases is sustained.
To reflect the foregoing,
Decision in docket No.
2203-05L will be entered under
Rule 155.
Decision in docket No.
23547-06L will be entered for
respondent.
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Last modified: March 27, 2008