Keith and Cherie Orum - Page 19

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          verification that the requirements of applicable law and                    
          administrative procedures have been met, and “whether any                   
          proposed collection action balances the need for the efficient              
          collection of taxes with the legitimate concern of the person               
          that any collection action be no more intrusive than necessary.”            
          Sec. 6330(c)(3).                                                            
               Petitioners raise issues only as to collection alternatives,           
          in that they dispute respondent’s rejection of another                      
          installment agreement and rejection of an offer-in-compromise.              
          We review the determination for an abuse of discretion because              
          the underlying tax liability is not at issue.  Lunsford v.                  
          Commissioner, 117 T.C. 183, 185 (2001); Nicklaus v. Commissioner,           
          117 T.C. 117, 120 (2001).                                                   
               Respondent’s rejection of another installment agreement for            
          petitioners was not an abuse of discretion.  Installment                    
          agreements are based upon the taxpayer’s current financial                  
          condition.  See 2 Administration, Internal Revenue Manual (CCH),            
          sec. 5.19.1.5.4.1, at 18,299-65.  Respondent’s determination was            
          based on information petitioners provided to Ms. Vuicich.  See              
          Schulman v. Commissioner, T.C. Memo. 2002-129.  At the section              
          6330 hearing, Ms. Vuicich requested from Mr. Orum additional                
          financial information by August 9, 2002, for the Appeals Office             
          to consider Mr. Orum’s request for another installment agreement.           
          Petitioners failed to timely respond to Ms. Vuicich’s request.              






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