- 11 - See Schulman v. Commissioner, T.C. Memo. 2002-129. Appeals Officer Otterson offered petitioner an alternative to the second OIC. Appeals Officer Otterson advised petitioner that respondent would be able to accept an installment agreement that would pay off petitioner’s tax liability. Appeals Officer Otterson told petitioner to let him know if petitioner was interested in discussing this possibility. Petitioner, however, did not contact Appeals Officer Otterson regarding an installment agreement. Respondent’s determination was based on a financial analysis of petitioner’s income, assets, and allowable expenses and his ability to pay. See id. Petitioner offered to pay less than $5,000 on a liability that as of January 26, 2001, was in excess of $18,000.6 Respondent gave due consideration to collection alternatives. See id. We conclude that respondent’s 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. See 5(...continued) outstanding tax liabilities. 6 Furthermore, we note that the amount petitioner offered to pay also is thousands of dollars less than the total amount of petitioner’s assessed tax liabilities, excluding penalties and interest, listed on the Forms 4340.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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