Roy and Margaret Eliason - Page 4




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               In a letter of May 31, 2000, respondent’s Appeals Office               
          confirmed to petitioners the proposed payment plan of $912 per              
          month and requested that petitioners respond before June 23,                
          2000, with any additional financial information that may differ             
          from the information already provided.                                      
               Petitioners did not provide to respondent’s Appeals Office             
          any additional financial information, petitioners did not offer             
          to respondent’s Appeals Office any alternatives to collection               
          other than an indefinite postponement for the due dates of the              
          proposed installment payments, and petitioners did not accept the           
          above proposed payment plan of $912 per month.                              
               On November 28, 2000, respondent’s Appeals Office issued to            
          petitioners separate notices of determination sustaining                    
          respondent’s proposed levy collection action.                               
               During 2000, and before respondent’s Appeals Office issued             
          to petitioners the above notices of determination, petitioners              
          received $10,000 in insurance proceeds relating to an automobile            
          accident, and petitioners used the $10,000 as a downpayment on a            
          new home.  Petitioners did not use any portion of the $10,000 to            
          make a payment on their 1994 and 1995 Federal income tax                    
          liabilities.                                                                
               Herein, petitioners assert that it was an abuse of                     
          discretion for respondent’s representative:  (1) To propose that            
          petitioners agree to a payment plan of $912 per month; (2) to               






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