Edward F. Murphy - Page 9

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               On the attachment, she calculates the amount she believes              
          that petitioner can pay in much the same way that, in the March             
          19 letter, she calculated what she described as an acceptable               
          offer in compromise (at least $97,884).  The only apparent                  
          difference is that she reduced her estimate of petitioner’s                 
          monthly net business income from $2,618 to $2,356.  She                     
          concludes:  “The reasonable collection potential based on the               
          income and expense figures provided by Mr. Murphy and calculated            
          utilizing allowable expenses and accepted practices is                      
          $82,164.00.”  She recommends that petitioner’s offer in                     
          compromise be rejected.                                                     
               With respect to balancing the need for the efficient                   
          collection of the taxes due with the concern that the collection            
          action be no more intrusive than necessary, she concludes:  “This           
          analysis indicates that this action is now necessary to provide             
          for the efficient collection of the taxes despite the potential             
          intrusiveness of enforced collection.”                                      
               Ms. Boudreau’s proposed disposition of petitioner’s case was           
          approved by her supervisor on May 19, 2003.                                 
               On May 23, 2003, Ms. Boudreau returned a telephone call from           
          Mr. Burke.  She informed him that she had rejected the offer in             
          compromise because it was too low and had closed the case because           
          of missed deadlines.  Mr. Burke said petitioner was ill and had             
          finally permitted him to disclose the nature of his illness                 






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