Case: No Abuse of Discretion in Rejection of Collection Alternatives (T.C. Memo) (IRC §6330)

IRS Settlement Officer (SO) did not abuse her discretion in rejecting collection alternative where a taxpayer declined to supply the requisite financial information and allowed the taxpayer 120 days to make full payment before closing the case and issuing the notice of determination, the U.S. Tax Court held in a memorandum opinion. Taxpayer sought a review of an IRS determination to uphold a notice of intent to levy and attempted to challenge his tax liabilities. Taxpayer offered to fully pay his outstanding balance in four monthly installments but never did and failed to pay estimated taxes for the years at ...