The IRS didn’t arbitrarily reject a delinquent taxpayer’s plan to partially pay his tax liabilities because it concluded after balancing for his necessary expenses that he could pay those liabilities in full, the US Tax Court said Thursday.
An IRS appeals officer concluded that George Kosmides “could pay a substantially higher amount” under the Internal Revenue Manual’s collection guidelines than the taxpayer offered to under his proposed partial payment installment agreement, according to the Tax Court. That conclusion wasn’t an abuse of discretion, the court said, because the officer adequately considered issues that Kosmides raised before disallowing some of his ...
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