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determined that petitioners had the ability to pay $5,243 per
month and could fully pay or provide a significant partial
payment through the liquidation of their assets.
Section 6502(a)(1) provides a 10-year period of limitations
on collection after assessment of tax, but section 6502(a)(2)(A)
also provides that respondent may extend the collection period in
connection with granting installment agreements. Respondent’s
policy limits Collection Statute Expiration Date (CSED)
extensions to 5 years beyond the original CSED for each tax
account. 2 Administration, Internal Revenue Manual (CCH), sec.
5.14.2.1, at 17,523. Thus, the Appeals officer correctly advised
petitioners that a $1,500 monthly installment agreement would not
satisfy petitioners’ $605,330 liability within the original CSED
plus 5 years for each tax account.
Respondent rejected the proposed $1,500 monthly installment
agreement in the aforementioned Notice. The Appeals officer
based his decision on the period of limitations and respondent’s
Internal Revenue Manual which provides:
If taxpayers have the ability to fully or
partially satisfy * * * [their] accounts by:
• using cash;
• withdrawing cash from bank or other accounts;
• borrowing on equity in real or personal property;
or,
• selling real or personal property, then:
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Last modified: May 25, 2011