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received several amended offers. The first amended offer in
compromise, dated April 30, 2001, proposed to settle the 1993
through 1999 tax years with a $20,000 deferred payment, payable
in monthly installments of $277. The second amended offer in
compromise, dated May 7, 2001, proposed to settle the same years
with a $24,500 deferred payment, payable in 96 monthly
installments of $255. The third amended offer in compromise,
dated May 17, 2001, proposed to settle the same years with an
$11,760 deferred payment, payable in 60 monthly installments of
$200.
Throughout the period when petitioner submitted these offers
in compromise, the Appeals officer remained firm on his original
terms.4 However, after submitting the second amended offer in
compromise, petitioner raised a question as to the amount of
transportation costs allowed in the calculation of his disposable
income. Rather than the $70 for transportation costs originally
claimed on petitioner’s Form 433-A, petitioner now argued that he
was entitled to a $352 per month transportation expense.
Petitioner’s counsel raised the transportation expense issue in a
letter, stating in pertinent part:
4 The Appeals officer communicated with petitioner’s
counsel on May 1 and 14, 2001, in writing, and additionally by
telephone, that petitioner’s submissions did not meet
respondent’s terms specified in the telephone conference.
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Last modified: May 25, 2011