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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.
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