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was sustained and that petitioners should consider either
refinancing or selling their residence to pay their 1999 Federal
income taxes.
The Appeals officer further determined that it was not
appropriate to levy on petitioners’ bank accounts because
petitioners had no funds in their bank accounts.1
The Appeals officer on his own initiative considered other
collection alternatives. In particular, the Appeals officer
determined that an installment agreement would not be appropriate
because petitioners’ monthly necessary living expenses exceeded
their monthly income. The Appeals officer further determined
that an offer-in-compromise would not be appropriate because of
the amount of equity in petitioners’ residence.
The Appeals officer determined that it was appropriate to
levy on petitioners’ residence because there was sufficient
equity in the residence to satisfy petitioners’ entire
outstanding tax liability.
On or about May 11, 2006, respondent’s notice of
determination was mailed to petitioners, sustaining respondent’s
proposed levy.
In the notice of determination, the Appeals officer
determined, and petitioners do not dispute, that as of May 2006,
1The record does not explain what disposition petitioners
made of the $359,378 in short-term capital gains they realized in
1999.
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