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$207,567 exceeded petitioners' outstanding tax liabilities, the
offer specialist recommended that petitioners' offer-in-
compromise of $67,000 be rejected.
The Appeals officer accepted the offer specialist's
recommendations. On June 10, 2002, the Appeals officer sent
petitioners a letter explaining that their $67,000 offer-in-
compromise would not be accepted because review indicated the
entire outstanding balance of their tax liabilities could be
collected over time. The letter explained that, in such
circumstances, an installment agreement was the available
collection alternative.
Based on the offer specialist's calculations, the Appeals
officer proposed that petitioners make an initial lump-sum
payment of $40,000,6 and monthly payments of $2,8207 commencing
July 26, 2002. The letter further advised petitioners that,
because their case had been under consideration since 2000, and
an installment agreement had been determined to be the available
alternative to a levy, their failure to accept the terms of the
6 The Appeals officer's case memorandum indicates that he
disregarded the $1,600 equity in petitioners' automobiles
postulated by the offer specialist, concluding that their net
realizable equity consisted only of the $40,000 equity in their
residence as found by the offer specialist.
7 The offer specialist had computed petitioners' monthly
future income as $2,813. While the record does not disclose the
basis on which the Appeals officer increased this figure to
$2,820 for purposes of the installment agreement he proposed, we
conclude that the difference is immaterial.
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