- 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.
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