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lien or levy is, as Judge Easterbrook concluded, “the sort of
decision committed to executive officials.” Orum, 412 F.3d at
821. That the IRS has exercised that discretion by limiting
compromises based on doubt as to collectibility to those
taxpayers suffering from real financial hardship, rather than to
those trying to give the IRS tsuris by making multiple lowball
offers and frustrating efforts to chase assets that have possibly
moved offshore is perfectly reasonable.
Because there are no grounds on which to overturn the filing
of the NFTL, it is sustained and
Decision will be entered for
respondent.
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Last modified: March 27, 2008