Robert A. Wodarczyk - Page 9




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               Monthly total income                                                   
               Net business income                $  477.00                           
               Monthly excess deposits             1,739.17      $2,216.17            
               ($17,391.66/10 months)                                                 
               Monthly total expenses                                                 
               National standard expenses1        $  383.00                           
               Housing and utilities         400.00                                   
               Transportation                     70.00                               
               Taxes (income & FICA)         120.00                                   
               Life insurance                     34.50                               
               Child support                         217.50      (1,225.00)           
               Disposable income                            $  991.17                 
                    1The Internal Revenue Manual provides procedures for              
               evaluating proposed installment agreements and offers in               
               compromise.  See 2 Administration, Internal Revenue Manual             
               (CCH), sec. 5.15.1 to 5.15.1.4, at 17,653-17,660.  Those               
               procedures contain guidelines for allowable expenses, which            
               include necessary and conditional expenses.  Necessary                 
               expenses are those reasonable expenses that provide for a              
               taxpayer’s and his or her family’s health and welfare and/or           
               the production of income.  Id. sec. 5.15.1.3.2, at 17,656.             
               There are three types of necessary expenses: (1) Those based           
               on national standards; e.g., food, housekeeping supplies,              
               apparel and services, and personal care products and                   
               services; (2) those based on local standards; e.g., housing,           
               utilities, and transportation; and (3) other expenses, which           
               are not based on national or local standards; e.g., health             
               care.  Id. sec. 5.15.1.3.2.1 to 5.15.1.3.2.3, at 17,656-               
               17,657.                                                                

               Petitioner’s original offer in compromise, dated August 31,            
          2000, proposed to settle the 1993 through 1999 years with a                 
          single cash payment of $720.  In a telephone conference, the                
          Appeals officer informed petitioner’s counsel that he could                 
          recommend an offer in compromise for $24,000, payable in 48                 
          monthly installments of $500.  Thereafter the Appeals officer               





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