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he was financially unable to make payments. While the record is
silent as to petitioner’s income at the time that the present
motion was filed, we note that neither petitioner nor his
representative offered evidence showing that petitioner did not
still possess the assets or maintain the income level as
reflected on his Federal income tax return for 2003.
Mr. Callanan, however, gave full consideration to
petitioner’s situation, repeatedly offering petitioner the
alternative of installment payments. In fact, Mr. Callanan
revisited petitioner’s financial statement and determined that
because the amount of liabilities owed was $18,277.54, petitioner
could request an installment payment option. Mr. Callanan then
proposed an installment payment whereby petitioner would pay $375
per month. When Mr. Callanan presented this installment payment-
option to petitioner, it was summarily rejected.
The record is replete with examples of how Mr. Callanan was
more than accommodating to petitioner throughout his dealings
with him. In sum, we are convinced that Mr. Callanan verified
that applicable law and administrative procedures had been met,
and determined that the proposed collection action balanced the
need for the efficient collection of taxes with the legitimate
concern of the taxpayer that any collection action be no more
intrusive than necessary.
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Last modified: November 10, 2007