Alan M. and Marcia F. Schulman - Page 17

                                       - 17 -                                         
                                  Attachment - 3193                                   
                               Notice of Determination                                

          Settlement Officer Ursula Kordasiewicz Wastian has not had prior            
          contact with the taxpayers concerning this specific tax return or           
          the years listed.  No other Collection Due Process Appeals are              
          pending at this time for the specific tax returns or years                  
          Notice of Intent to Levy Issued on 4/9/2001.  The taxpayers                 
          submitted a Request for a Collection Due Process Hearing on                 
          ISSUES RAISED BY THE TAXPAYER                                               
          The taxpayer is requesting an installment agreement or an offer             
          in compromise be granted based on financial information he                  
          submitted to the compliance employee and again to the Settlement            
          Officer.  The Service does consider both collection alternatives            
          after an analysis of income and monthly expenditares [sic]                  
          claimed on a Collection Information Statement.  Certain                     
          restrictions do apply in that expenses considered reasonable and            
          allowable under the Internal Revenue Manual are granted and the             
          taxpayer must be in full compliance with all Federal Tax Return             
          filing requirements.                                                        
          The taxpayers submitted financial information to the compliance             
          function and to appeals which contained expenses not normally               
          allowable in the area of unsecured debt.  The Internal Revenue              
          Manual permits a taxpayer a one year period of time to adjust               
          their spending habits and life-style to allow for payment in full           
          of accrued liabilities over the life of an installment agreement.           
          A proposal of initial payments in the amount of $75.00 per month            
          to be increased to $750.00 at the one year anniversary was made             
          to the taxpayers.  They do not agree with this proposal and did             
          not counter with anything more viable.                                      
          Additionally, the Service could not seriously entertain an                  
          installment agreement or an offer in compromise until the                   
          taxpayer became current with all filing requirements.  The 1999             
          and 2000 Federal Income Tax Returns remain unfiled.                         
          A review of the compliance case history reveals the Revenue                 
          Officer communicated the Services’ policy regarding allowable               

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Last modified: May 25, 2011