Edie D. Glass - Page 5

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               Installment Agreement on or about January 1, 2000.  The                
               taxpayer made these monthly payments on a reasonably                   
               regular basis until February 27, 2002.                                 
               Given the aggregate amount of the taxpayer’s liability                 
               at the time the installment agreement was initiated,                   
               her contention that the balance due was ‘never                         
               decreasing’ is essentially correct ($1,200 paid per                    
               year would do little more than pay the interest of the                 
               aggregate liability).  However, this would indicate                    
               that the installment agreement itself was ‘faulty’ in                  
               that the creator of the agreement should have set a                    
               much greater monthly payment in order to liquidate the                 
               aggregate liability within a reasonable time span.                     
               This retrospective observation, however, in no way                     
               addresses whether or not levy action is appropriate, as                
               the taxpayer has not expressed any interest in                         
               modifying the terms of an installment agreement in                     
               order to fully pay the remaining outstanding                           
               On May 29, 2003, the Appeals Office issued the Notice of               
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330, notifying petitioner of the determination to proceed           
          with collection of the outstanding liabilities for the 1992,                
          1993, 1995, and 1996 taxable years.                                         
               This Court has jurisdiction to review the Commissioner’s               
          administrative determination under section 6330.  Sec. 6330(d).             
          Where, as here, the validity of the underlying tax liability is             
          not at issue,3 we review the determination for abuse of                     
          discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza           

               3  Indeed, it appears from respondent’s records that                   
          petitioner signed a waiver of assessment with respect to the 1993           
          and 1995 taxable years.                                                     

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