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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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