- 33 - remain unpaid, after crediting their accounts in accordance with this Opinion. VI. Whether the Appeals Officer Abused Her Discretion A. Installment Agreement At some point before Appeals Officer Janice Rich was assigned to petitioners’ section 6330 case, petitioners proposed to pay $4,000 each month or $12,000 each quarter towards their 1997 and 1998 unpaid income tax liabilities. In a letter dated November 2, 2000, Revenue Officer F. Stevens informed petitioners that respondent could not accept their proposal, partly because they were not current in filing Federal tax returns. Petitioners argue that respondent’s failure to accept their payment proposal was an abuse of discretion. Petitioners allege that respondent’s own actions precluded petitioners from filing returns in subsequent tax years. Petitioners fail to explain, however, how respondent’s actions precluded them from filing tax returns. On the record before us, we find petitioners’ allegation implausible. In any event, respondent cited numerous reasons for rejecting petitioners’ payment proposal, including their ability to make full or significant payment of all taxes due, their failure to submit collection information statements, and their failure to include all outstanding tax years. Finally, there is no indication in the record that petitioners proposed their payment plan in the Appeals hearing. Generally, this CourtPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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