- 19 - information in the administrative file is more than 12 months old and/or the information is no longer accurate. After petitioners failed to appear for their September 12, 2001, face-to-face hearing, the Appeals officer informed petitioners through their representative that he did not have sufficient financial information to make a determination on their installment agreement proposal. Then the Appeals officer invited petitioners to submit additional information to assist in his consideration of their proposed installment agreement, but petitioners never sent him any information. Despite the Appeals officer’s multiple requests to either petitioners or their representative, petitioners did not submit updated financial information. As a result, we find that the Appeals officer could have reasonably rejected an installment agreement proposal by petitioners on account of their failure to timely provide the requested information. See Orum v. Commissioner, supra. Given petitioners’ failure to provide the requested updated financial statement, respondent considered the financial statement in determining whether to accept petitioners’ proposed installment agreement. If petitioners had paid $800 a month for 5 years pursuant to their proposed installment agreement, only $48,000 would have been paid towards their total outstanding liability of $55,362.13. Since they did not offer an alternative installment proposal, the revenue agent calculated a reasonable paymentPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011