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
DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER
SECTION 6320 and/or 6330”.
Frank Agostino and Julia F. Moore, for petitioners.
Joseph J. Boylan, for respondent.
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