Allen Charles Schenkel - Page 5




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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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