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determination).1 The issue for decision is whether there was an
abuse of discretion in the determination that collection action
could proceed for 1998 and 1999 (years in issue).
Background
All of the facts have been stipulated. The stipulated facts
and the attached exhibits are incorporated herein by this
reference.
Petitioners resided in Warren, Ohio, at the time they filed
the petition. As of May 15, 2003, petitioners owed tax
liabilities of $25,398 and $6,683 for 1998 and 1999,
respectively, including additions to tax and interest.
The tax liabilities for the years in issue resulted from
petitioners’ failure to make sufficient quarterly payments of
estimated taxes to cover the taxes that resulted from bonuses
received by Mr. Crisan. Petitioners proposed an installment
agreement with monthly payments of $100. Respondent rejected
this proposal as “unrealistic and unreasonable” given the size of
the tax liabilities.
When no installment payment amount could be agreed to by the
parties, respondent issued each petitioner a Final Notice of
Intent to Levy and Notice of Your Right to a Hearing on January
25, 2001. On February 20, 2001, petitioners sent respondent a
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
Amounts are rounded to the nearest dollar.
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