Richard T. and Catherine L.. Lites - Page 5

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          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 the                    






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