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updated financial statements. See Orum v. Commissioner, supra at
13.
B. Respondent Did Not Abuse His Discretion Upholding the
Proposed Collection Actions and Rejecting Petitioners’
Proposed Installment Agreement During the Hearing
for the 1997-99 Taxable Years
Petitioners argue that respondent abused his discretion in
rejecting the terms of their proposed installment agreement for
the taxable years 1997-99 of $800 per month over 5 years and
sustaining the proposed collection actions. Petitioners’ main
reasons are that (1) the Appeals officer arbitrarily set an amount
that was suitable for petitioners to pay monthly, and (2) the
Appeals officer did not fully take into account the financial and
health conditions of petitioners. We disagree.
The primary flaw in petitioners’ argument is that petitioners
failed to provide more updated financial information despite the
Appeals officer’s repeated requests.4 The Appeals officer
properly followed the administrative procedures requiring him to
request a new or updated financial statement if the financial
4Petitioners allege that there is an updated 2002 financial
statement on file with the Appeals office. Respondent is not
aware of the existence of such a document. Although this Court’s
review is not limited to the evidence in the administrative
record, Robinette v. Commissioner, 123 T.C. 85 (2004),
petitioners did not introduce such evidence at any juncture,
including at trial. We merely have petitioners’ assertion that
it exists. Therefore, because of the lack of substantive
documentation of this alleged financial statement and
petitioners’ failure to introduce it into evidence for this Court
to consider, we are unable to acknowledge its existence.
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