- 7 - situation. Respondent’s calculation was based on a financial analysis of petitioners’ monthly net income generated by Dr. Castillo’s medical practice and real estate investments. Respondent has the discretion to accept or reject an installment agreement proposed by a taxpayer under section 6159. Sec. 301.6159-1(b)(1)(i), Proced. & Admin. Regs. Section 6159 requires respondent to enter into installment agreements in certain circumstances not applicable to the facts before us. See sec. 6159(c). Respondent’s rejection of the proposed installment agreement on the grounds that it would not satisfy petitioners’ liability within the period of limitations on collection after assessment contained in section 6502, plus allowable extensions, is not an abuse of discretion. See McCorkle v. Commissioner, T.C. Memo. 2003-34. IV. Section 6330(c)(3)(C) Balancing Test Petitioners argue that respondent failed to balance the Government’s need for the efficient collection of taxes with the concern of the “person”, i.e., petitioners in this case, that any collection action be no more intrusive than necessary. Petitioners also assert that respondent’s reliance on 2 Administration, Internal Revenue Manual, sec. 5.14.1.4(6), at 17,508, was a violation of section 6330(c)(3)(C). We are unpersuaded by these arguments.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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