- 5 - petitioners stated that they had a combined monthly income of $8,924 and total expenses of $7,546. On January 21 and February 26, 2004, the Appeals officer spoke by telephone with petitioner concerning payment of petitioners’ outstanding tax liabilities. Petitioner requested that he be allowed to pay petitioners’ tax liability in monthly installments of $700. The Appeals officer advised petitioner that she could not consider an installment agreement calling for monthly payments of $700 unless the balance due for all years was reduced to $25,000 or less. Petitioner told the Appeals officer that he could not pay the $4,000 required to reduce the balance to $25,000. The Appeals officer informed petitioner that since he could not bring the balance to $25,000, any new installment agreement would require petitioners to pay monthly installments in an amount equal to the amount of their available income after necessary expenses. The Appeals officer suggested that petitioners borrow against the equity in their real property and/or other assets to pay the balance in full. Petitioner did not agree to the alternatives suggested by the Appeals officer. Petitioners did not raise any spousal defenses. The IRS Appeals Office issued a notice of determination dated April 2, 2004, sustaining the proposed collection by levy.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011