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In addition, the Appeals officer exercised proper discretion
in rejecting petitioners’ proposed installment agreement because
petitioners were not in full compliance with their filing and
payment obligations. See Orum v. Commissioner, 412 F.3d at 820;
McCorkle v. Commissioner, T.C. Memo. 2003-34 (citing IRM pt.
5.14.1.4.1 (July 1, 2002), pt. 5.14.9.3(5) (Mar. 30, 2002), pt.
5.19.1.3.3.1(1) and (5) (Oct. 1, 2001), pt. 5.19.1.5.4.10(1)-(2)
(Oct. 1, 2001)). Petitioners were delinquent in paying their
joint income tax liability for the taxable year 2000 and had not
made any estimated tax payments for the taxable year 2001.
Therefore, respondent did not abuse his discretion in denying
petitioners’ proposed installment agreement.
C. Respondent Did Not Abuse His Discretion Upholding
the Proposed Collection Actions and Rejecting
Petitioners’ Proposed Installment Agreement During the
Collection Due Process Hearing for the 2000 Taxable
Year
During petitioners’ hearing for the taxable year 2000, they
proposed an installment agreement whereby they would fully pay
their outstanding tax liabilities in equal monthly installments
over 5 years. Petitioners contend that respondent abused his
discretion by rejecting their proposed installment agreement.
Petitioners’ position is without merit because of their
repeated failure to provide respondent with updated financial
statements. See Orum v. Commissioner, 123 T.C. at 13. During the
course of the communications associated with the hearing for the
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