Alan M. and Marcia F. Schulman - Page 8




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               are also actual payments being made on outstanding                     
               credit card balances.                                                  
               I am again requesting a compromise monthly payment at a                
               level that can be made on a regular basis.  If we are                  
               not able to reach a compromise, than I am requesting to                
               take the next step in the appeal process.                              
          The letter attached a new Form 433-A, which listed the following            
          amounts as necessary living expenses:                                       
               Item of expense               Expense claimed                          
               National standard expenses    $1,473                                   
               Housing/utilities             1,715                                    
          Transportation                     1,045                                    
               Health care                   589                                      
              Taxes (income and FICA)       1,685                                    
               Court-ordered payments        150                                      
          Child/dependent care                                                        
               Life insurance                60                                       
               Secured/legally-perfected debts                                        
               Other expenses                                                         
               Loan payments       685                                                
               Student loans            210                                           
               Total                         7,612                                    
               On July 19, 2001, a Form 3193, Notice of Determination                 
          Concerning Collection Action(s) Under Section 6320 and/or 6330,             
          was issued to petitioners in which the Appeals Office “sustained”           
          the notice of intent to levy and verified that “All                         
          administrative procedures were followed prior to issuance.”4  On            
          July 30, 2001, petitioners filed a timely petition with this                
          Court from that determination.  On August 28, 2001, petitioners             
          filed an amended petition in which they disagreed with the                  
          settlement officer’s proposed monthly installment payment and               



               4An attachment to this form describes the determination to             
          sustain the levy and is attached to this opinion as an appendix.            





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