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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 settlement
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Last modified: May 25, 2011