Edie D. Glass - Page 7

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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               
               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                     

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