- 23 - remand this case to the Commissioner, whom the law authorizes to make installment agreements. Lunsford v. Commissioner, 117 T.C. 183, 189 (2001); see Harrell v. Commissioner, T.C. Memo. 2003-271 (concluding that the issuance of a notice of determination was an abuse of discretion and remanding the matter to the Commissioner for the sole purpose of allowing the taxpayer to pursue collection alternatives), motion for reconsideration denied T.C. Memo. 2003-312. We shall remand this matter to the Commissioner for the sole purpose of reconsidering petitioners’ $1,200 per month installment agreement proposal or such other collection alternatives as petitioners might now wish to offer. In evaluating any such collection alternatives, the Commissioner should consider petitioners’ current financial circumstances, petitioners’ current paying and filing compliance, and any other relevant factors. The Commissioner should also take into account, to the extent relevant, applicable amendments to section 6159(a), which authorize partial payment installment agreements. Petitioners may not further challenge the imposition of the section 6651(a)(1) and (2) additions to tax or raise any new or additional issues beyond offering collection alternatives. To reflect the foregoing, An appropriate order will be issued.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011