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liabilities to be paid in full prior to the time Mr. Lites would
be expected to retire and there would be no requirement that the
collection statute expiration date (CSED) be extended.”
Petitioners increased their installment agreement offer to
$1,000 per month. The Appeals officer also rejected this offer.
In a letter to petitioners’ counsel dated September 5, 2003, the
Appeals officer stated:
Regarding your request for an installment
agreement of $1,000/mo., I do not feel the amount
requested is adequate. Based on Mr. Lites’ age, health
concerns and the likelihood that he could retire prior
to full payment, I do not feel that it would be in the
best interest of the taxpayer or the Government to
accept this amount. If Mr. Lites were to retire at 65,
it is extremely unlikely that Mrs. Lites would be able
to maintain this agreement based on what appears to be
limited work experience. In addition, the taxpayers
would be required to extend the collection statute
expiration date (CSED) to at least the year 2014. It
is my opinion that the granting of an installment
agreement in the amount requested would place an undue
burden on both of the taxpayers when the liabilities
can be paid in full by 2007 if the taxpayers were to
enter into an agreement in the amount indicated in my
letter of August 25, 2003. Based on this discussion I
will be unable to honor your request for the agreement
in the amount of $1,000/mo.
If the taxpayers do not wish to accept an
installment agreement for $2,700/mo. please advise me
no later than September 12, 2003.
In her September 5, 2003, letter, the Appeals officer agreed
to abate the section 6651(a)(1) addition to tax for failure to
timely file for 1999. The Appeals officer declined to consider
petitioners’ request to abate the section 6651(a)(1) addition to
tax for 2000 on the ground that petitioners had “presented no
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Last modified: May 25, 2011