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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 Court
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