- 15 -
On February 14, 1997, petitioner faxed Mr. Marine a letter
dated February 13, 1997. The letter acknowledged:
The rejection of my offer is based largely upon the
surplus between my living expenses as you have
calculated them and my current monthly income. A
significant part of that evaluation involves the
government-imposed housing expense limit of $1500.00[1]
per month, which as you indicated is in reality quite
low.
1Actually, $1,568.
The letter also proposed that petitioners’ outstanding liability
“be capped at the original amount of the remaining tax balance,
$29,600,8 payable in 60 equal monthly payments of $500.00".
By letter dated February 18, 1997, Mr. Marine advised
petitioner that his proposal to “cap” petitioners’ outstanding
liability could not be honored because of the statutory
requirement that “interest and penalty be collected on delinquent
liabilities.” The letter concluded as follows:
As we discussed in our recent telephone conversation,
your ability to make payments (based on Offer in
Compromise criteria) is the major stumbling block in
the consideration of your offer. Your “life-style
choices”, although commendable, on the expenditure of
your available funds will always be a deterrent.
The offer program is meant for those who truly do not
have the assets or ability to pay. Clearly, this is
not the case with you.
Should you have any further questions, please feel free
to contact me. Perhaps an installment agreement can be
made with the office closest to you.
8 Actually, $29,742. See supra p. 4.
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