Robert A. Wodarczyk - Page 15




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          the subsequently claimed $352 per month.  See id. sec.                      
          5.15.1.3(8)(a), at 17,655 (“A taxpayer is required to provide               
          evidence and justification for claimed expenses, except National            
          Standards.”).  On these premises, the Court finds respondent’s              
          computations to be reasonable and finds no abuse of discretion by           
          respondent.  Schulman v. Commissioner, T.C. Memo. 2002-129.                 
               With respect to petitioner’s contention that respondent                
          provided no independent review before rejecting petitioner’s                
          third amended offer in compromise, there was also no abuse of               
          discretion.  Contrary to petitioner’s contentions, respondent did           
          have an independent reviewer, the Appeals team manager, review              
          the offer in compromise.  This review occurred after the revenue            
          officer’s verification and the Appeals officer’s analysis and               
          recommendations.  Petitioner was given the one hearing to which             
          he was entitled under section 6330(b)(2), where he was                      
          represented by counsel.  Petitioner’s contention is rejected.               
               In sum, petitioner’s third amended offer in compromise was             
          considered in detail.  Respondent followed standard guidelines on           
          the calculation of petitioner’s monthly disposable income, giving           
          due consideration to each of the points raised by petitioner.               
          The record shows that respondent properly considered and                    
          addressed the statutory criteria in analyzing petitioner’s third            
          amended offer in compromise.  Ultimately, respondent concluded              
          that such offer did not fairly represent petitioner’s ability to            





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