- 7 - failed to balance the need for the efficient collection of taxes with the concern that the collection action be no more intrusive than necessary. Based on the foregoing, we hold that respondent’s determination to proceed with the collection of petitioner’s tax liabilities for 1990, 1991, 1994, 1995, 1996, 1997, 1998, and 2002 was not an abuse of discretion.3 To reflect the foregoing, An appropriate decision will be entered. 3At trial, petitioner testified that his income and expenses have changed since the filing of the collection information statement. As of Dec. 8, 2005, petitioner testified that he earned a $125,000 per year salary from Rosenthal Acura, that petitioner’s housing and utilities expenses had risen to $5,000 per month, and that petitioner’s health care expenses had risen to $700 per month. Petitioner offered at trial to make a lump sum payment of $50,000 and monthly installment payments of $900. We note that the aforementioned changes to petitioner’s income and expenses, even were we to consider them, would not alter our decision that respondent’s determination did not constitute an abuse of discretion.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011