Daniel J. Ford - Page 5

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          610 (2000).  We understand petitioner to contend that the failure           
          of respondent’s Appeals Office to accept a collection alternative           
          constitutes an abuse of discretion.                                         
               During the section 6330 hearing, petitioner and Appeals                
          Officer Kowalkowski reviewed petitioner’s Form 433-A, Collection            
          Information Statement for Wage Earners and Self-Employed                    
          Individuals (collection information statement), dated November              
          27, 2002.  On the collection information statement, petitioner              
          reported that he received monthly wage income of $9,500 as                  
          Finance Director of Rosenthal Acura and incurred the following              
          monthly expenses:                                                           
                         Item                          Amount                         
                    Food, clothing, and misc.          $1,000                         
                    Housing and utilities              2,000                          
                    Transportation                     600                            
                    Health care                        290                            
                    Taxes (income and FICA)            1,828                          
                    Court-ordered payments             500                            
                    Child/dependent care               200                            
                    Life insurance                     210                            
                    Other expenses                     2,000                          
                   Total Living Expenses              8,628                          
          Based upon the aforementioned income and expenses, Appeals                  
          Officer Kowalkowski determined that an acceptable installment               
          agreement would require monthly payments of approximately $1,900            
          rather than the $900 monthly payments proposed by petitioner                
          prior to the section 6330 hearing.  In addition to the                      
          possibility of an installment agreement, petitioner and Appeals             
          Officer Kowalkowski discussed the opportunity for petitioner to             

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