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MEMORANDUM OPINION
NIMS, Judge: This case arises from a petition for judicial
review filed in response to a “NOTICE OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330” (Notice).
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure. The parties do not challenge the Court’s jurisdiction
over this case. Petitioners do not dispute their liability for
underlying taxes, interest, and penalties. The sole issue for
decision is whether respondent’s rejection of petitioners’
proposed installment agreement constitutes an abuse of
discretion.
Background
The parties submitted this case without trial pursuant to
Rule 122. The stipulations of the parties, with accompanying
exhibits, are incorporated herein by this reference. At the time
the petition was filed in this case, petitioners resided in
Oakland, New Jersey.
Petitioner Hector Castillo is a physician with investments
in real estate and other business ventures. Petitioner Mooneem
Castillo is not employed outside the home. Petitioners filed
joint Forms 1040, U.S. Individual Income Tax Returns, for the
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Last modified: May 25, 2011