- 7 - In evaluating petitioner’s original offer in compromise, the revenue officer reviewed bank statements and canceled checks from petitioner’s business and personal checking accounts. He found that petitioner had commingled his business and personal funds in these accounts. The revenue officer also found that petitioner’s bank deposits exceeded the sources of income shown on his original offer in compromise. For the 10-month period reflected on the “Income and Expense Analysis” section of the Form 433-B, the actual deposits into the business account ($42,861.66) exceeded the reported sources of income on the original offer in compromise ($25,470) by $17,391.66. The revenue officer returned the case to the Appeals officer with his findings. The revenue officer calculated petitioner’s future monthly disposable income, described by respondent as an estimate of a taxpayer’s ability to pay based on an analysis of gross income, less necessary living expenses, for a specific number of months into the future, to be $991.17.3 That calculation provided for $70 in monthly transportation expenses (as claimed on petitioner’s Form 433-A), accounted for the excess deposits, reflected the net income from petitioner’s business, and allowed various other expenses. The calculation was as follows: 3 The revenue officer made other findings and calculations which need not be detailed here.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011