Hector Castillo and Mooneem Castillo - Page 1

                                 T.C. Memo. 2004-238                                  

                               UNITED STATES TAX COURT                                

                HECTOR CASTILLO AND MOONEEM CASTILLO, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2557-03L.               Filed October 14, 2004.             

                    Ps filed a petition for judicial review pursuant to               
               sec. 6330, I.R.C., in response to a determination by R to              
               proceed with collection by levy of assessed income tax                 
               liabilities plus penalties and interest for 1992, 1993,                
               1994, 1996, 1997, 1998, and 1999.                                      
                    Held:  R’s rejection of an installment agreement                  
               proposed by Ps did not constitute an abuse of                          
               discretion, and R’s determination that Ps could pay                    
               $5,243 per month was reasonable.                                       
                    Held, further, R may proceed with collection of                   
               balances due as determined in a “NOTICE OF                             
               SECTION 6320 and/or 6330”.                                             

               Frank Agostino and Julia F. Moore, for petitioners.                    
               Joseph J. Boylan, for respondent.                                      

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