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Also, information obtained by the settlement officer
indicated that, just prior to the above 1996 purchase of the real
estate, petitioners sold a house in Nashville, Tennessee.
Petitioners did not provide to the settlement officer requested
information regarding the disposition of the proceeds from the
sale of the Nashville house.
Based on valid and unresolved concerns regarding ownership
of the real estate on which petitioners’ mobile home residence
was located, the settlement officer rejected petitioners’ offer
in compromise of $180 per month and calculated a minimum
acceptable offer in compromise from petitioners of $529 per month
for 116 months, until a total of $61,364 would be paid. In
preparing computations of this new minimum amount for an
acceptable offer in compromise from petitioners, the settlement
officer used a fair market value for the real estate of $82,300,
based upon a 2001 local property tax appraisal. The settlement
officer calculated petitioners’ net realizable equity in the real
estate at $39,840.
Petitioners disputed the settlement officer’s decision to
consider the equity in the real estate in evaluating their offer
in compromise. Petitioners, however, did not submit to
respondent’s settlement officer information sufficient to resolve
the settlement officer’s question regarding ownership of the real
estate.
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Last modified: May 25, 2011