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judicial review under section 6330(d)(1)(A) from that
determination. The only issue for decision is whether the
settlement officer abused her discretion in failing to accept
petitioners’ collection alternative.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing of
the petition, petitioners resided in Bayside, Wisconsin.
Petitioner Alan Schulman is employed as a C.P.A., and his
wife is an educator. As of January 11, 2001, petitioners owed
unpaid Federal income taxes, penalties, and interest as follows:
Tax period Unpaid assessment amount
1993 $4,701.17
1994 3,733.13
1995 6,102.33
1996 6,492.48
1997 8,226.46
1998 6,097.53
On January 11, 2001, respondent rejected petitioners’
proposed installment agreement to pay $75 per month for their
unpaid tax liabilities. Respondent estimated that petitioners’
monthly income was $6,639, consisting of Mr. Schulman’s salary of
$3,856 and his wife’s salary of $2,783. Respondent estimated
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