James J. Crisan and Veronica L. Crisan - Page 7

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               Petitioners raise issues only as to collection alternatives,           
          in that they dispute respondent’s rejection of their proposed               
          installment agreement and rejection of an offer in compromise.              
          We review the determination for an abuse of discretion because              
          the underlying tax liability is not at issue.  Lunsford v.                  
          Commissioner, 117 T.C. 183, 185 (2001); Nicklaus v. Commissioner,           
          117 T.C. 117, 120 (2001).                                                   
               Respondent’s rejection of petitioners’ proposed installment            
          agreement was not an abuse of discretion.  Installment agreements           
          are based upon the taxpayers’ current financial condition.  See 2           
          Administration, Internal Revenue Manual (CCH), sec. 5.19.1.5.4.1,           
          at 18,299-50.  Respondent’s determination was based on the                  
          information provided to the Appeals officer by petitioners.                 
          Schulman v. Commissioner, T.C. Memo. 2002-129.  At the hearing,             
          respondent preliminarily computed a monthly payment amount of               
          $1,200.  The Appeals officer gave petitioners the opportunity to            
          resubmit a monthly installment payment amount, to which                     
          petitioners failed to timely respond.  We find that the Appeals             
          officer could have reasonably determined that petitioners’                  
          proposed installment payment of $100 per month should be rejected           
          on the basis of petitioners’ submitted income and expense                   
          information.                                                                
               Additionally, respondent’s determination not to enter into             
          an offer in compromise agreement with petitioners was not an                






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