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that a collection alternative such as an installment agreement or
offer-in-compromise is more appropriate, respondent is not
required to offer petitioner a collection alternative acceptable
to petitioner before determining that a lien is an appropriate
collection tool. In this case, petitioner had the burden of
demonstrating that a collection alternative was appropriate and
that respondent abused his discretion by rejecting the collection
alternative.
On the record before us, we cannot conclude that the
settlement officer abused her discretion in determining that the
lien was appropriate to safeguard respondent’s collection of
petitioner’s unpaid taxes. Petitioner did not argue at his
hearing or at trial that respondent should have accepted one or
more of his three offers-in-compromise, and he did not introduce
the offers into evidence at trial. Petitioner made payments for
approximately a year and a half of about $1,000 per month. After
2 full years of nonpayment, petitioner submitted several Forms
433-A showing net monthly income ranging from more than $2,000
per month to $355 per month. The settlement officer finally
determined that petitioner could pay $1,250 per month.9
9Although petitioner subsequently submitted a revised Form
433-A showing monthly net income of $355, we are satisfied that
the settlement officer did not abuse her discretion in concluding
that petitioner could pay $1,250 per month. Petitioner estimated
his expenses and did not apply the applicable national and local
(continued...)
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