- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011