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Respondent also determined that the proposed installment
plan would be difficult to monitor. We agree. Because
petitioner’s net income fluctuates monthly, respondent would be
forced to audit continually the correctness of the income and
deductions petitioner claimed. Furthermore, the proposed
installment plan left uncertain whether petitioner would fully
pay her outstanding liabilities within the periods of limitations
on collection. We conclude that respondent gave due
consideration to the proposed installment plan, and his
determination was reasonable.
Petitioner has failed to raise a spousal defense or make a
valid challenge to the appropriateness of respondent’s intended
collection action. These issues are now deemed conceded. Rule
331(b)(4). Accordingly, we conclude that respondent did not
abuse his discretion by refusing to accept the proposed
installment plan, and we sustain respondent’s determination to
proceed with collection with respect to petitioner’s 1997 and
1999 tax years.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011