Hector Castillo and Mooneem Castillo - Page 4

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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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