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officer did not abuse her discretion in computing petitioners’
allowable monthly expenses.
On the basis of the record as a whole, it is clear that the
parties were, and are still, unable to agree to an appropriate
monthly installment payment. The settlement officer’s proposed
monthly installment payment was computed under the guidelines
provided in the Internal Revenue Manual. We have reviewed those
computations, and we find them to be reasonable. The settlement
officer’s disallowance of petitioners’ claimed expenses was not
arbitrary, and she gave due consideration to each of the
proposals they submitted. We hold that the settlement officer
did not abuse her discretion, and respondent may proceed with the
proposed levy action. See Estate of Doster v. Commissioner, T.C.
Memo. 2002-2 (“To the extent respondent considered installment
10(...continued)
A I don’t know if they were given to her, but
somebody in the Service, in the office, had them, yes.
In a notice to Ms. Marge Flaig, who, I guess, was the
revenue officer who you had before, in an attachment to
Form 12153 in April of 2001, it listed health care for
insurance, health insurance, dental and prescription
copays.
* * * * * * *
Q And did you submit any additional information
beyond this, in terms of where these line items
consisted of?
A No. Nobody ever asked me.
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