Davis and Lois Etkin - Page 19

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        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 payment                   






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