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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.
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