Daniel J. Ford - Page 6

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          submit an offer-in-compromise or to discharge the tax liabilities           
          in bankruptcy.  Appeals Officer Kowalkowski and petitioner did              
          not agree to a collection alternative during the section 6330               
          hearing.  However, Appeals Officer Kowalkowski agreed to send               
          petitioner transcripts of petitioner’s accounts for each tax year           
          in issue and to consider collection alternatives proposed by                
          petitioner as of January 14, 2005.  Although Appeals Officer                
          Kowalkowski subsequently mailed the transcripts, petitioner did             
          not submit a collection alternative for Appeals Officer                     
          Kowalkowski’s consideration.                                                
               As noted above, Appeals Officer Kowalkowski had no                     
          involvement with respect to the unpaid tax liabilities prior to             
          the section 6330 hearing.  Based on our review of the record, we            
          conclude that Appeals Officer Kowalkowski’s determination that an           
          acceptable installment agreement would require monthly payments             
          of $1,900 is not an abuse of discretion.2  Petitioner did not               
          challenge the appropriateness of the intended method of                     
          collection or raise a spousal defense.  Furthermore, petitioner             
          has made no contention and offered no evidence that Appeals                 
          Officer Kowalkowski either failed to properly verify that all               
          applicable laws and administrative procedures were followed or              

               2As noted above, petitioner did not submit a collection                
          alternative for the consideration of respondent’s Appeals officer           
          either during or after the sec. 6330 hearing.  Furthermore,                 
          petitioner offered no credible evidence to demonstrate that                 
          petitioner could not pay $1,900 per month.                                  

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