- 7 - The only argument that petitioners set forth in their petition is their disagreement with respondent’s calculation of a reasonable installment payment. Petitioners’ disagreement primarily rests on their assertions that (a) respondent overstated the amount of petitioners’ income in prior years, (b) petitioners’ income is subject to change due to petitioner’s age and the temporary nature of his employment, and (c) petitioners’ expenses are likely to increase, especially in light of certain medical expenses. We need not address the individual amounts which entered into respondent’s calculation. Petitioners have maintained that they are unable to make more than a $50 monthly payment, an amount that respondent did not abuse his discretion in rejecting. We therefore hold that respondent’s issuance of the notice of determination was not an abuse of discretion and respondent may proceed with collection of the tax liability by levy upon petitioners’ property. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011