Pamela J. Ellison - Page 15

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          $3,554 (after subtracting for outstanding loans).  They also                
          owned two cars (a 2001 Ford Windstar and a 1990 Honda Civic)                
          worth a total of $12,790 (with no outstanding loans on the                  
          vehicles); a 1998 Sea-Doo GTi 3-Pass, a 1997 Sea-Doo GTi 3                  
          3-Pass, and a Kawasaki VN 1500-D2 Vulcan Clsc worth a total of              
          $9,160 (with no outstanding loans on the vehicles); they were               
          leasing a 2002 Ford Ranger; and they had no personal assets                 
          (i.e., zero).                                                               
               In determining the current value of their Form 433-A                   
          investments, petitioner and Mr. Ellison valued them at 60 percent           
          of the face value even though the Form 433-A states:  “Current              
          Value:  Indicate the amount you could sell the asset for today.”            
          In determining the current value of their real estate, petitioner           
          and Mr. Ellison valued their home at “80 percent quick sale                 
          value” even though the Form 433-A states:  “Current Value:                  
          Indicate the amount you could sell the asset for today.”                    
               Under the monthly income and expense analysis on Form 433-A,           
          petitioner and Mr. Ellison listed monthly wages of $4,688 for Mr.           
          Ellison, monthly wages of $1,977 for petitioner, and monthly                
          interest/dividends of $33 for total monthly income of $6,698.               
          Under total living expenses, petitioner and Mr. Ellison listed              
          $1,290 for food, clothing, and miscellaneous; $1,583 for housing            
          and utilities; $617 for transportation; $1,452 for taxes; $210              








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