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officer refused to accept it. The case records indicate that Ms.
Dellosso refused to accept an installment agreement restricted to
the years for which petitioner had requested a section 6330
hearing, but advised petitioner that she could pay what she
wanted to pay. The case records also note that petitioner had
not provided a Form 433A disclosing her financial information.
Ms. Dellosso’s position on the installment agreement, as
recorded in the case records, is in accord with pertinent
provisions of the Internal Revenue Manual (IRM). See IRM sec.
5.14.2.2, sec. 5.14.1.5.1. The Court has generally upheld
collection determinations made by the Commissioner in accord with
the IRM. See Etkin v. Commissioner, T.C. Memo. 2005-245 (and
cases cited therein).
Petitioner has some prior experience in dealing with the
IRS, unpleasant though it may have been. Had petitioner wanted
to fully pay the outstanding liabilities for the 3 years at issue
here, she could have done so just as she did in making the
earlier $35,000 payment. If she has not done so already, she may
yet choose to pay the liabilities.
Conclusion
Because petitioner did not present viable alternatives to
collection, the Court finds that respondent’s determination to
pursue the intended collection action was not an abuse of
discretion.
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Last modified: May 25, 2011