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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.
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Last modified: May 25, 2011