Mark Fowler and Joylyn Souter-Fowler - Page 7

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          petitioners’ desire to compromise all of the liabilities.  The              
          Appeals officer requested more information from petitioners,                
          which they timely provided with a copy of their filed 1999                  
          Federal income tax return.  At some time in the process,                    
          petitioners submitted an amended offer in compromise for $2,400,            
          to be paid in $100-monthly installments.  Under those terms, the            
          $2,400-offer could be paid in full in 2 years.                              
               On October 16, 2001, respondent’s Appeals officer sent                 
          petitioners a letter informing them that he had reviewed the                
          offers in compromise.  The Appeals officer determined that the              
          minimum offer to compromise both the individual and joint                   
          liabilities should be a total of $2,400.  The Appeals officer               
          used petitioners’ estimate of their primary vehicle3 to calculate           
          a quick sale value of $2,400, which was determined to be the                
          minimum acceptable offer.  The Appeals officer then attempted to            
          determine whether petitioners would be able to meet the monthly             
          installment offer obligation.  In calculating petitioners’                  
          financial capability, the Appeals officer used petitioners’                 
          submitted monthly gross income figure of $4,608, but did not use            
          petitioners’ submitted $3,989 monthly expense figure.  Instead of           
          using the $3,989 expense figure provided by petitioners, the                
          Appeals officer used $4,644, an estimated amount based on                   

               3 Petitioners estimated the value of their primary vehicle             
          to be $3,000.  Respondent used this figure to calculate the                 
          $2,400 quick sale value.                                                    

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