- 21 - of petitioner’s monthly income and expenses and ability to pay in considering an appropriate collection alternative. We found petitioner to be a conscientious taxpayer trying to fulfill his Federal income tax obligations, and, in light of the facts and circumstances of this case, respondent’s failure to fully consider an installment agreement or other collection alternative was not justifiable. Accordingly, we hold that it was an abuse of discretion to issue the notice of determination under these circumstances. We shall remand this matter to the Appeals Office for the sole purpose of considering an installment agreement or other collection alternative. Petitioner may not further challenge respondent’s determination not to abate interest or the imposition of the additions to tax under sections 6651(a)(2) and 6654(a) or raise any new or additional issues beyond offering a collection alternative. Conclusion We have considered all of the other arguments made by the parties, and, to the extent that we have not specifically addressed them, we conclude that they are without merit.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011