- 19 - review at the hearing, Appeals Officer Mares could not properly consider an installment agreement at that time. See Wells v. Commissioner, T.C. Memo. 2003-234.19 Accordingly, we conclude that respondent’s determination with respect to collection alternatives was not an abuse of discretion. Petitioner has failed to demonstrate that the proposed levy action is inappropriate, another collection alternative is more appropriate, or some other relevant issue adversely affects respondent’s proposed collection activity. We therefore conclude that respondent’s determination to proceed by levy with the collection of petitioner’s 1980 income tax liability was not an abuse of discretion. We have considered the remaining arguments of both parties for results contrary to those expressed herein and, to the extent not discussed above, find those arguments to be irrelevant, moot, or without merit. To reflect the foregoing, Decision will be entered for respondent. 19We also note that, for purposes of this proceeding, petitioner did not introduce into evidence any information regarding his financial condition that would suggest a remand is appropriate. See Wells v. Commissioner, T.C. Memo. 2003-234.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011