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$15,780, Appeals Officer Marble disallowed the expense for a
watchdog, noted that petitioner appeared “to have used ‘net’
(rather than ‘gross’) income” on her offer in compromise, and
calculated petitioner’s total gross monthly income to be $4,195.
Indeed, when the Court asked petitioner to explain why she
disagreed with respondent’s analysis of her offer in compromise,
petitioner failed to provide an adequate explanation.
Petitioner also contends that she should not have any tax
liabilities for the 1992 taxable year because of her monthly
payments. Respondent determined that payments of approximately
$100 per month from January 2001 to February 2002 were
insufficient to extinguish her reported tax liability of $7,022,
exclusive of interest and penalties, for the 1992 taxable year.
We are satisfied that respondent did not abuse his discretion in
making his determination.4
Reviewed and adopted as the report of the Small Tax Case
Division.
To give effect to the foregoing,
Decision will be entered
for respondent.
4 During the hearing of this case, petitioner advised the
Court that she would submit an amended or new offer in compromise
based upon her discussions with respondent. The Court encouraged
petitioner to follow through with respondent. At the time of
writing this opinion, the Court has not received any information
concerning the submission of an amended or new offer in
compromise.
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