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under the reason for submission of the offer--doubt as to
liability, doubt as to collectibility, or effective tax
administration. Petitioner again checked the box for “Short Term
Deferred Payment Offer (offered amount paid in more than 90 days
but within 24 months)”. He listed the monthly payment as $200,
the monthly payment date as “30th Deduction From Pay”, and the
date the offered amount will be paid in full as “6/2003".
Around this time, respondent received a completed Form 433-A
from petitioner. Petitioner listed a balance in his bank
accounts--including a checking account, a savings account, a
section 401(k) account, and a mutual fund--of $11,178.49.
Petitioner also listed two cars and two boats, which he owned
outright, as assets. Petitioner listed his monthly income to be
$2,881 and his total monthly living expenses to be $2,535--$460
for national standard expenses,2 $960 for housing and utilities,
$400 for transportation, $660 for income and FICA taxes, $42 for
union dues, and $13 for “emply com fund”.
Appeals Officer Otterson reviewed the second OIC based on
the financial information submitted by petitioner. Appeals
Officer Otterson, however, calculated petitioner’s total
allowable monthly living expenses to be $2,409--$554 for national
2 National standard expenses are for clothing and clothing
services, food, housekeeping supplies, personal care products and
services, and miscellaneous. See Schulman v. Commissioner, T.C.
Memo. 2002-129 n.6.
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Last modified: May 25, 2011