- 5 - On June 8, 2001, respondent’s settlement officer sent petitioners the following letter regarding the proposed installment agreement: I have not received a more viable proposal for payment of your 1993 thru 1998 (and 1999) Federal Income Taxes. As we discussed during our telephone conference on 5/21/2001, although you do not demonstrate an ability to pay in full within the near future, an adjustment of your expenses should be made so that within one year you can commence substantial payments to allow payment in full of all the liabilities listed on the Notice of Intent and the 99 and prospective 2000 tax debt. An installment agreement in the amount of $75.00 could be initially allowed which would increase to $748.00 per month in one year. I am sorry, but the unsecured and incidental debt you list in your April 2001 financial statements * * * [is] not allowable when forbearance would result in payment in full of all tax liabilities, penalty and interest. The standards for allowable living expenses are prescribed in the Internal Revenue Manual are the guide used by both the Compliance and Appeals functions. I cannot * * * [forgo] these guidelines unless there is a special circumstance such as critical health needs. In response to this letter, petitioners submitted a Form 433-A, Collection Information Statement for Individuals, dated June 20, 2001, in which they stated: “I would like to reach a compromise between the $75 that was previously agreed to + the $735 [sic] that the IRS has calculated.” The Monthly Income and Expense Analysis, as part of that form, lists monthly income of $6,965, which consists of Mr. Schulman’s salary of $3,965 and his wife’s salary of $3,000, as well as the following expenses:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011