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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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Last modified: May 25, 2011