- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011