George Thompson v. Commissioner

140 T.C. No. 4

UNITED STATES TAX COURT GEORGE THOMPSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10897-09L. Filed March 4, 2013. P filed a petition for review pursuant to I.R.C. sec. 6330 in response to R’s determination to proceed with collection. P sought a collection alternative of a partial payment installment agreement with a monthly payment of $3,000. The Internal Revenue Manual provides guidance for determining how much a taxpayer should be able to pay in a partial payment installment agreement and how much should be set aside for the taxpayer’s necessary…