- 3 - 2001, petitioners’ counsel met with a settlement officer from respondent’s Appeals Office. Petitioners’ counsel requested that respondent allow petitioners to partially satisfy their cumulative liability by means of an installment agreement. The settlement officer correctly advised petitioners’ counsel that, under respondent’s policy, an installment agreement would be acceptable only if the payments thereunder would satisfy in full the total amount of the cumulative liability within the applicable periods of limitation, plus any allowable extensions. Petitioners did not offer to make payments to respondent in an amount sufficient, within the applicable periods of limitation plus allowable extensions, to fully satisfy the cumulative liability, which, at that time, totaled approximately $125,000. As a result, respondent rejected petitioners’ proposed installment agreement. On July 17, 2001, petitioner personally met with the settlement officer. At that meeting, petitioner requested that respondent designate the cumulative liability as currently not collectible (i.e., as uncollectible), and the settlement officer considered the revisions petitioner submitted to his financial information. After considering the revisions, the settlement officer concluded that petitioners had disposable monthly income of $348 and that petitioners could afford to make payment to respondent of $180 per month. As a result, the settlementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011