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APPENDIX
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
listed.
Notice of Intent to Levy Issued on 4/9/2001. The taxpayers
submitted a Request for a Collection Due Process Hearing on
4/14/2001.
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.
VERIFICATION OF LEGAL AND PROCEDURAL REQUIREMENTS
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