Ronald J. and June M. Speltz - Page 24

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               The Appeals officer considered and adjusted the financial              
          information submitted by petitioners and concluded that                     
          petitioners could pay the balance of their tax liability by use             
          of an installment agreement.  See generally Orum v. Commissioner,           
          123 T.C. 1, 13-14 (2004).  Neither the information provided to              
          the Appeals officer nor that provided to the Court in this case             
          shows that it was not reasonable for the Appeals officer to                 
          conclude that petitioners have the ability to pay over time the             
          balance of the tax liability.  Petitioners contend that they                
          should not be required to pay the full amount.  We are not                  
          unsympathetic to the burdens and lifestyle changes that                     
          petitioners have and may suffer as a result of their tax                    
          liability.  Petitioners have not contended or shown, however, any           
          invalidity in the Appeals officer’s determination of their basic            
          living expenses as that term is used in section 7122.                       
          Petitioners seek to have the Court redefine “hardship”, “special            
          circumstances”, and “efficient tax administration” in a manner              
          different from that set forth in the regulations and in the                 
          Internal Revenue Manual.                                                    
               There is a dispute between the parties with respect to the             
          individual adjustments used by the Appeals officer in determining           
          that petitioners could pay the remaining tax liability under an             
          installment plan.  Respondent has suggested some revised                    
          computations and a remand for further consideration of                      






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