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on your age, health, and the age of the tax
liabilities. * * *
Mr. Kane and Mr. Galvin also met on November 9, 2001, to
discuss collection alternatives. The $721 offer made by Mr. Kane
was not accepted, and Mr. Galvin offered no other collection
alternatives.
On December 28, 2001, a notice of determination was sent to
petitioners which stated:
It has been determined that the proposed levy action is
sustained. The Internal Revenue Service has complied
with code and procedural requirements in collecting the
tax.
* * * * * * *
The only issue that you raised was that you
could not pay $790 per month that was determined by the
revenue officer to be required. After updating your
income and expense information it was determined that
payments of $721 per month would be required. The
problem is that some of your expenses do not fall
within the IRS allowable expense guidelines. These
include tuition and related expenses for your children
and credit card debt payments.
An installment agreement is not possible because
payments of even $721 per month would never fully pay
the liabilities. The IRS can only grant an installment
agreement that provides for full payment within the
statutory period for collection. An installment offer
in compromise was discussed in detail but you have not
pursued this alternative. The proposed levy action is
therefore sustained.
On January 24, 2002, petitioners filed a Petition for Lien
or Levy Action Under Code Section 6320(c) or 6330(d). On
February 21, 2002, petitioners filed an Amended Petition for Lien
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