Olen W. and Gwendolyn Wilborn - Page 11

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          contentions regarding items such as deductions for 1997 are not             
          properly at issue and cannot be addressed here.  Petitioners have           
          also expressly conceded any challenge to the balance due for                
          1996.  We therefore review respondent’s determination solely for            
          abuse of discretion.                                                        
          III.  Review for Abuse of Discretion                                        
               With respect to issues subject to review in collection                 
          proceedings for abuse of discretion, petitioners have at no time            
          raised a spousal defense.  Nor have they offered any specific,              
          concrete collection alternatives.  Although petitioners in their            
          petition generally allude to the possibility of selling or                  
          mortgaging real property, they have not proposed any actual plan            
          or arrangements for satisfying their tax liabilities.  They also            
          apparently broached at their Appeals hearing but failed to follow           
          through on borrowing funds to pay a portion of the debt.  Hence,            
          the record does not reveal that respondent inappropriately                  
          rejected any bona fide collection alternative.                              
               Concerning challenges to the appropriateness of collection             
          actions, the petition complains about intrusiveness.  To the                
          extent that this complaint pertains to the levy action, the issue           
          is not before us.  To the extent that the complaint can be                  
          interpreted to encompass the lien action, we conclude that, in              
          light of the absence of any definite collection alternatives, the           
          filing of a lien properly balances the competing concerns of                
          efficient collection and intrusiveness.                                     




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