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In support of their grounds for effective tax
administration, petitioners revisited the facts and circumstances
of their prior Tax Court proceeding. Petitioners claimed that
they cannot pay the tax in full because they have a substantial
amount of short-term debt, the expenses of deferred maintenance
on their home, and the need to fund their retirement savings over
a limited number of years.
As to doubt as to collectibility, petitioners pointed to the
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, they submitted to Ms. Clinger. On
their Form 433-A, petitioners indicated that they owned their
home located in Riverside, California, which they valued at
$350,000 with mortgages of $331,290. Petitioners also have
retirement accounts valued at $24,815.65 and bank accounts valued
at $606.75. Petitioners indicated that their monthly income is
$10,834 and their monthly expenses are $12,571. Monthly expenses
of $4,473 are attributable to petitioners' debts.
Ms. Clinger's analysis of petitioners' monthly income over
allowable expenses revealed the following:
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Last modified: May 25, 2011