- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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