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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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Last modified: May 25, 2011