- 13 - second offer was inadequate. Petitioner argues that respondent’s haste in filing the notices of lien shows that respondent was predisposed to reject petitioner’s second offer. Respondent, however, filed the Federal tax lien 1 week after petitioner’s second offer was returned, and we are not persuaded that in doing so respondent failed to properly consider petitioner’s second offer or abused his discretion in any other manner. Amongst petitioner’s numerous arguments only one has any potential for success--his allegation that he was suffering from economic hardship when he submitted the second offer. Petitioner relies on the internal revenue manual to support his position that even if he has the ability to pay the liability, an offer- in-compromise may be accepted if he suffers from economic hardship. See 1 Administration, Internal Revenue Manual (CCH), sec. 5.8.11.2.1, at 16,385-5. Factors related to economic hardship may include: (1) Long-term illness, medical condition, or disability may render the taxpayer incapable of earning a living, (2) the taxpayer may have a set monthly income and no other means of support, and the income is exhausted each month Less: Expenses (3,384) Disposable income (276) Multiple x 48 Value of income (13,248) Reasonable collection 36,045Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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