HOWARD, Circuit Judge.
Edward F. Murphy owed federal income taxes in excess of $250,000 for 1992-2001. He offered to settle this liability by paying $10,000. The Internal Revenue Service (IRS) rejected Murphy's offer, concluding that he could afford a larger settlement payment. Murphy appealed to the United States Tax Court, which upheld the IRS's ruling. Murphy now appeals the Tax Court's decision. We affirm.
I.
In April 2002, the IRS issued Murphy...
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