-6-
We note that the action of the Appeals officer is consistent
with the Commissioner’s current administrative guidelines for
installment agreements for business tax liabilities. Those
guidelines condition the Commissioner’s acceptance of an
installment agreement on the ability of the taxpayer to pay
current and delinquent taxes as well as operating expenses.
Internal Revenue Manual, pt. 5.14.7.2(4)b (March 30, 2002).
Those guidelines also state that a taxpayer must be in current
compliance with return filing requirements to qualify for an
installment agreement. Id. at pt. 5.14.7.2(4)i.
We sustain respondent’s determination to proceed with
collection with respect to petitioner’s 1997 and 1998 taxable
years. We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011