Theodore C. and Denise M. Schwartz - Page 6

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          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           

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