- 5 - Under section 6330(d)(1), we have jurisdiction to review respondent’s notice of determination relating to a section 6330 hearing. Where the underlying Federal income tax liability is not at issue, we review for abuse of discretion respondent’s determination adverse to a taxpayer sustaining respondent’s collection activity. Sego v. Commissioner, 114 T.C. 604, 610 (2000). Petitioner argues that respondent’s Appeals Office should have granted petitioner an installment agreement. Because, however, petitioner had a history of noncompliance with his Federal income tax obligations and was not compliant with his current tax obligations as of the date of the Appeals Office hearing, respondent’s Appeals Office did not abuse its discretion in declining to grant petitioner an installment agreement. See Orum v. Commissioner, 412 F.3d 819, 821 (7th Cir. 2005), affg. 123 T.C. 1 (2004) (no abuse of discretion when rejecting an installment agreement from a taxpayer who had a history of not fulfilling Federal income tax obligations); Rodriguez v. Commissioner, T.C. Memo. 2003-153 (no abuse of discretion when rejecting an offer-in-compromise from a taxpayer who had not filed current and previous returns); Londono v. Commissioner, T.C. Memo. 2003-99 (no abuse of discretion when rejecting an offer-in-compromise from a taxpayer who had a history of not fulfilling Federal income tax obligations); McCorkle v.Page: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007