Alan M. and Marcia F. Schulman - Page 11

                                       - 11 -                                         
          settlement officer informed petitioners that, under those                   
          procedures, she could not allow expenses for unsecured debt as              
          they had claimed.  She also informed them that certain other                
          expenses they had claimed had not been substantiated.  She                  
          provided petitioners considerable time and opportunity to submit            
          additional information to substantiate expenses they had                    
          previously claimed, but which were disallowed, and to submit                
          evidence of any “special circumstance”.  The settlement officer             
          offered a 1-year period for petitioners to modify their spending            
          habits and lifestyle before full monthly payments would be                  
               Petitioners submitted additional information, however, they            
          continued to claim expenses which were previously disallowed and            
          which they had been told could not be allowed.  They did not                
          provide substantiation for certain expenses, e.g., medical                  
          expenses, but, nevertheless, they continued to claim those                  
          expenses.  Petitioners’ letter of July 6, 2001, shows clearly               
          that an installment agreement could not be reached by the parties           
          given the wide disparity in petitioners’ claimed expenses and the           
          expenses allowable under the Internal Revenue Manual guidelines.            
          Indeed, in that letter petitioners claimed expenses in amounts              

          necessary expense test, but which may be allowable if the tax               
          liability, including projected accruals, can be fully paid within           
          five years.                                                                 

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