Gunter R. and Jay R. Wall - Page 8

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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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