Mark Fowler and Joylyn Souter-Fowler - Page 13

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          expenses.  Petitioners made an estimate of $3,000 for the value             
          of their primary car and the Appeals officer used this figure to            
          calculate the quick sale value of $2,400.  Based on this premise,           
          the Appeals officer determined that an offer of $2,400 would be             
          an appropriate amount to settle the outstanding liabilities due             
          for 1990-92 and 1994-96.  The Appeals officer requested a lump-             
          sum payment through the sale of petitioners’ primary vehicle.               
          Petitioners rejected this approach as this was their primary                
          vehicle and to sell it would have caused great financial harm.              
               Petitioners submitted an amended offer in compromise for               
          $2,400, to be paid in $100 monthly installments.  Under those               
          terms, the $2,400 compromise could be paid in full in 2 years.              
          That offer was rejected due to the Appeals officer’s                        
          determination that petitioners were financially unable to make              
          the payments.  We note that petitioners had cooperated with all             
          requests from the Internal Revenue Service in an attempt to                 
          resolve this matter.                                                        
               Appeals officers, in the consideration of an offer in                  
          compromise should verify that the requirements of applicable law            
          and administrative procedures have been met, and “whether any               
          proposed collection action balances the need for the efficient              
          collection of taxes with the legitimate concern of the person               
          that any collection action be no more intrusive than necessary.”            
          See sec. 6330(c)(3)(C).  The verification of applicable law and             

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