- 7 -
petitioners’ case had previously rejected. The only financial
information available to the Appeals officer in the
administrative record was a Form 433-A, Collection Information
Statement (the financial statement), that petitioners submitted
in October 2000 to the revenue agent reviewing their case. This
statement reflected total monthly income of $15,630.77 and total
monthly expenses of $16,816.01. On the basis of the information
provided in the financial statement and the procedures of the
Internal Revenue Manual (IRM), the revenue agent disallowed
certain expenses and determined that petitioners could afford to
pay $4,912 per month for the first year and $7,106 per month
thereafter. By the time the Appeals Office reviewed petitioners’
case, the financial statement was more than 12 months old and
thus outdated. Given the age of the financial statement, the
information on petitioners’ 2000 income tax return, and the
Appeals officer’s conversations with petitioners’ representative,
the Appeals officer determined that the financial statement did
not reflect their current financial status. The Appeals officer
informed petitioners’ representative that he did not have
sufficient financial information to make a determination as to
their installment agreement proposal and requested updated
financial information. Petitioners’ representative informed the
Appeals officer that he could not rely on the financial statement
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011