- 34 -
his claimed expenses, she found that, from his net monthly income
alone, he could, over time, afford to pay more than $10,000
towards the 1992-2001 liability.11 She also calculated that he
had net realizable equity of $30,204, which was more than the
$10,000 he had offered. She calculated a reasonable collection
potential of $82,164. Because the offer was less than the
reasonable collection potential she had calculated, the offer
was, in the absence of special circumstances, unacceptable under
the Commissioner’s procedures for the submission and processing
of offers in compromise. See Rev. Proc. 2003-71, sec. 4.02(2),
2003-2 C.B. 517. Petitioner has not challenged Rev. Proc. 2003-
71, supra. Moreover, petitioner provided Ms. Boudreau with
insufficient information to justify her accepting an offer based
on special circumstances in any amount less than what she had
calculated as the reasonable collection potential of the case.
Therefore, we must determine only whether the Appeals officer’s
calculations are reasonable. See, e.g., Galvin v. Commissioner,
T.C. Memo. 2003-263; McCorkle v. Commissioner, T.C. Memo. 2003-
34; Schulman v. Commissioner, T.C. Memo. 2002-129. We conclude
that her computations were reasonable, and she did not err in
11 Ms. Boudreau did not calculate the present value of his
net monthly income, and we are unsure whether her assumption in
calculating what petitioner could pay is that petitioner would
make installment payments. Taking into account any reasonable
interest rate, however, the present value of petitioner’s net
monthly income is still a substantial amount.
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