Omar Urbina Pineda - Page 22

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          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.                    












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