- 14 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011