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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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Last modified: May 25, 2011