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that additional information was needed. After receiving and
reviewing petitioners’ financial information, Revenue Officer
Griggs, in a letter dated March 18, 2002, informed petitioners
that she was unable to recommend that their offer be accepted
because the information petitioners provided indicated that they
could pay their entire income tax liabilities.3 The letter also
stated that if petitioners did not agree with the statements,
they could call her to discuss the offer or discuss other
collection alternatives.
Petitioners and Revenue Officer Griggs further corresponded
during March and May of 2002, in which petitioners submitted
additional financial information to her. On May 29, 2002, the
Revenue officer sent petitioners a letter stating that on the
basis of the new information provided, she had recalculated
petitioners’ financial situation. Because petitioners’ projected
income and net assets, as recalculated, still enabled them to pay
their tax liabilities in full, she would not recommend their
3 Revenue Officer Griggs determined that, after allowing for
necessary living expenses, petitioners’ monthly income and
realizable assets enabled them to make a maximum payment of
$1,168 per month. The Revenue officer stated that because she was
unable to reach petitioners she used their Dec. 31, 2000, income
to compute their monthly income. The officer determined that
petitioners had a total monthly income of $6,486 and expenses of
$5,318 leaving an ability to pay $1,168 per month over a period
of 4 years.
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Last modified: May 25, 2011