- 6 -
those issues, and “whether any proposed collection action
balances the need for the efficient collection of taxes with the
legitimate concern of the person that any collection action be no
more intrusive than necessary.” Sec. 6330(c)(3).
Petitioners raise only the issue of whether a collection
action is appropriate and argue that the collection action is
more intrusive than necessary. A petition filed under section
6330 must contain “Clear and concise lettered statements of the
facts on which the petitioner bases each assignment of error.”
Rule 331(b)(5). We generally consider “only arguments, issues,
and other matter that were raised at the collection hearing or
otherwise brought to the attention of the Appeals Office.”
Magana v. Commissioner, 118 T.C. 488, 493 (2002); sec. 301.6330-
1(f)(2), Q&A-F5, Proced. & Admin. Regs. Because petitioners do
not dispute the existence or amount of their underlying tax
liabilities, we review the determination for an abuse of
discretion. Lunsford v. Commissioner, 117 T.C. 183, 185 (2001);
Nicklaus v. Commissioner, 117 T.C. 117, 120 (2001).
The Appeals officer’s consideration and rejection of
petitioners’ collection alternative, an installment agreement,
was reasonable and not an abuse of discretion. Her determination
not to consider petitioners’ proposed installment agreement was
based on applicable procedures contained in respondent’s Internal
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: November 10, 2007