Bobby J. Prater - Page 6

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          efficient collection of taxes with a taxpayer’s concerns                    
          regarding the intrusiveness of the proposed levy action.  Sec.              
               Section 6330(d)(1) grants this Court jurisdiction to review            
          the determination made by the Appeals Office in connection with             
          the section 6330 hearing.  Where the underlying tax liability is            
          not in dispute, the Court will review the determination of the              
          Appeals Office for abuse of discretion.  Lunsford v.                        
          Commissioner, 117 T.C. 183, 185 (2001); Sego v. Commissioner,               
          supra at 610; Goza v. Commissioner, 114 T.C. 176, 182 (2000).  An           
          abuse of discretion occurs if the Appeals Office exercises its              
          discretion “arbitrarily, capriciously, or without sound basis in            
          fact or law.”  Woodral v. Commissioner, 112 T.C. 19, 23 (1999).             
               Petitioner does not dispute his underlying tax liabilities             
          for any of the relevant years.  Accordingly, we shall review                
          respondent’s determination for abuse of discretion.                         
               In his petition, petitioner alleges that he now has the                
          financial information requested by Officer Chapman and that the             
          Court should remand his case to the Appeals Office for                      
          consideration of payment through an installment agreement.                  
          Respondent asserts that the Appeals officer did not abuse his               
          discretion by rejecting an installment agreement because                    
          petitioner did not provide the requested financial information at           
          the section 6330 hearing.                                                   

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