- 13 -
189 (2001); Martin v. Commissioner, T.C. Memo. 2003-288.
Respondent, however, has expressed a willingness to discuss an
installment agreement with petitioners pursuant to proper
procedures. Under section 6330(d)(2), the IRS retains
jurisdiction of the collection action after the determination is
made, and a taxpayer may “request an installment agreement * * *
at any time before, during, or after the Notice of Intent to Levy
hearing.” H. Conf. Rept. 105-599, at 266 (1998), 1998-3 C.B.
747, 1020.
The Court has considered the remaining arguments raised in
petitioners’ pretrial memorandum and finds that they are
unconvincing.
Accordingly, the Court holds that the Appeals Office did not
abuse its discretion in determining that respondent’s proposed
levy should be sustained.
To reflect the foregoing,
Decision will be entered
for respondent.
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