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wife’s physical condition was the statement: “my wife is
unemployable. She is on Social Security Disability and earns no
income.” At that time, petitioner’s total outstanding tax
liability had increased to $38,165.32. Petitioner claimed on the
Form 433-A that he had a 25-percent interest in his home and
monthly net business income and living expenses of $2,550 and
$3,384, respectively.4 On Form 433-A, petitioner explained his
home ownership as follows: “As I borrowed my contribution toward
the purchase of the home, and as a result of the fact that my
wife’s assets were the basis for the ability to obtain the
mortgage in the first place, my interest in the house is 25%
while hers is 75%.” On June 17, 2002, respondent returned the
offer, stating that petitioner did not have any changed
circumstances and that the offer was not materially different
from the prior offer.
4 The total living expenses for both offers were calculated
by petitioner as follows:
Expense First Offer Second Offer
National standard1 $448 -0-
Housing/utilities 1,000 $2,042
Transportation --- 800
Health insurance premium 200 340
Taxes --- 100
Life insurance --- 102
Total 1,648 3,384
1 Includes clothing and clothing services, food,
housekeeping supplies, personal care products and services, and
miscellaneous.
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Last modified: May 25, 2011