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KERR v. COMMISSIONER

Dkt. No. 22838-04L.

93 T.C.M. 932 (2007)

T.C. Memo. 2007-43

Jerry Joe Kerr v. Commissioner.

United States Tax Court.

February 22, 2007.

Attorney(s) appearing for the Case

Joseph R. Borich III, for petitioner.

Dennis R. Onnen and James E. Cannon, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Pursuant to section 6330, petitioner seeks review of a proposed levy.1 The only issue is whether respondent's settlement officer abused his discretion in rejecting petitioner's offer to compromise his 1992 income tax liability.

FINDINGS OF FACT

The parties have stipulated some facts, which we incorporate herein by this reference. When he petitioned

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