- 5 - In response, petitioners timely filed a Form 12153, Request for Collection Due Process Hearing. Petitioners requested abatement of the statutory additions on the basis of reasonable cause and further requested an offer-in-compromise or, in the alternative, an installment agreement. Appeals Officer’s Conclusions During the Appeals process, the parties conducted a hearing through written correspondence and telephone conversations. As requested, petitioners submitted a completed Form 433-A, Collection Information Statement for Wage Earners and Self- Employed Individuals. On the Form 433-A, petitioners listed their assets and included an analysis showing total gross monthly income of $10,499 (including $500 wages for Catherine) and total monthly living expenses of $9,611. On the basis of this analysis, petitioners initially requested an installment agreement whereby they would pay $750 per month. The Appeals officer rejected this offer. By letter to petitioners’ counsel dated August 25, 2003, the Appeals officer stated that on the basis of the financial information petitioners had submitted, she had determined that petitioners had “excess monthly income” of $2,732 per month. The letter also stated that the Appeals officer had determined that petitioners would need to pay $2,700 per month if they wished to enter into an installment agreement. The letter further stated: “This amount would allow thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011