(petitioner owned bed and breakfast with spouse; $170,000 tax liability triggered upon sale for approximately $2 million because of failed I.R.C. Sec. 1031 exchange; before petitioner knew of tax liability sale proceeds used to buy apartment building; petitioner lived in one unit and elderly mother lived in another unit with three other units rented; IRS moved to seize apartment building and petitioner sought to pay on liability monthly while trying to find lender to refinance; IRS appeals rejected petitioner's offer and petitioner appealed; IRS conceded that appeals officer abused discretion by not asking for revised financial data; Tax Court remanded for supplemental hearing with appeals officer; new appeals officer failed to follow Tax Court's guidance and asserted that petitioner committed fraud and put lien on apartment building and suggested that IRS seize and sell building; IRS later determined that no fraud committed but rejected monthly payment arrangement because IRS claimed that petitioner could pay liability in full; case returned to Tax Court where court determined that IRS had made many errors and failed to gain sufficient information to support conclusion that petitioner's collection alternative not reasonable; IRS abused discretion by sustaining proposed levy against apartment building; Tax Court could not independently review whether proposed collection alternative is appropriate; case remanded to appeals for consideration of proposed payment arrangement, petitioner's financial information and whether hardship existed).