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On the attachment, she calculates the amount she believes
that petitioner can pay in much the same way that, in the March
19 letter, she calculated what she described as an acceptable
offer in compromise (at least $97,884). The only apparent
difference is that she reduced her estimate of petitioner’s
monthly net business income from $2,618 to $2,356. She
concludes: “The reasonable collection potential based on the
income and expense figures provided by Mr. Murphy and calculated
utilizing allowable expenses and accepted practices is
$82,164.00.” She recommends that petitioner’s offer in
compromise be rejected.
With respect to balancing the need for the efficient
collection of the taxes due with the concern that the collection
action be no more intrusive than necessary, she concludes: “This
analysis indicates that this action is now necessary to provide
for the efficient collection of the taxes despite the potential
intrusiveness of enforced collection.”
Ms. Boudreau’s proposed disposition of petitioner’s case was
approved by her supervisor on May 19, 2003.
On May 23, 2003, Ms. Boudreau returned a telephone call from
Mr. Burke. She informed him that she had rejected the offer in
compromise because it was too low and had closed the case because
of missed deadlines. Mr. Burke said petitioner was ill and had
finally permitted him to disclose the nature of his illness
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