- 9 - eliminating any expense as unnecessary or unsubstantiated, petitioners had at least $1,378 of monthly income available to pay their tax liabilities. Additionally, petitioners stated that the current value of their residence was $280,000, subject to a $79,000 mortgage, and that they owned other real property valued at $260,000. On the basis of the entirety of the record, we conclude that respondent did not abuse his discretion in determining that petitioners’ proposed installment agreement did not reflect their ability to pay. Petitioners’ tax liability, including projected accruals, would not be fully paid within 5 years under an installment agreement permitting monthly payments of $700. Petitioners have sufficient equity in their real property and other assets to pay the tax liability. Consequently, we are satisfied that respondent did not abuse his discretion in denying petitioners’ proposed installment agreement. This case was set for trial on June 10, 2005. During that proceeding petitioner gave respondent’s counsel a check for $4,000, and the parties and the Court agreed to continue the case until August 30, 2005, to allow petitioner time to attempt to make arrangements to pay the balance of the tax liabilities for the years at issue. 4(...continued) verify to the satisfaction of the IRS the amount claimed as their monthly expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011